IAPP CIPM Practice Test - Questions Answers, Page 8

An organization's business continuity plan or disaster recovery plan does not typically include a retention schedule for storage and destruction of information. A retention schedule is a document that specifies how long different types of information should be kept by an organization before they are disposed of or destroyed. A retention schedule is usually based on legal, regulatory, operational, historical, or archival requirements. A retention schedule is part of an organization's information governance or records management policy, not its business continuity or disaster recovery plan.

A business continuity plan (BCP) is a document that outlines how an organization will continue its critical functions and operations in the event of a disruption or disaster. A BCP usually includes:

Contact information and service level agreements (SLAs) for key personnel, stakeholders, providers, backup site operators, etc.

Business impact analysis (BIA) that identifies the potential impacts of disruption on all aspects of the business, such as financial, legal, reputational, etc.

Risk assessment that identifies and evaluates the likelihood and severity of various threats and vulnerabilities that could cause disruption or disaster.

Identification of critical functions that are essential for the survival and recovery of the business.

Communications plan that specifies how to communicate with internal and external parties during and after a disruption or disaster.

Testing plan that specifies how to test and update the BCP regularly to ensure its effectiveness and validity.

A disaster recovery plan (DRP) is a document that outlines how an organization will restore its IT systems, data, applications, and infrastructure in the event of a disruption or disaster. A DRP usually includes:

Recovery time objectives (RTOs) that specify how quickly each IT system or service needs to be restored after a disruption or disaster.

Recovery point objectives (RPOs) that specify how much data loss is acceptable for each IT system or service after a disruption or disaster.

Emergency response guidelines that specify how to respond to and contain a disruption or disaster, such as activating the DRP, declaring a disaster, notifying the stakeholders, etc.

Statement of organizational responsibilities that specifies who is responsible for what tasks and roles during and after a disruption or disaster, such as initiating the DRP, executing the recovery procedures, restoring the IT systems or services, etc.

Recovery procedures that specify how to recover each IT system or service from backup sources, such as backup tapes, disks, cloud services, etc.

Testing plan that specifies how to test and update the DRP regularly to ensure its effectiveness and validity.Reference:[Business Continuity Plan (BCP) Definition]; [Disaster Recovery Plan (DRP) Definition]

This answer is the best step to take next, as it can help you to assess the current state of the vendor's privacy practices and determine if they meet the organization's standards and expectations, as well as the applicable laws and regulations. Asking the vendor for verifiable information about their privacy protections can include requesting documentation, evidence or demonstration of how they collect, use, store, protect, share and dispose of personal data, what policies and procedures they have in place, what technical and organizational measures they implement, what certifications or audits they have obtained or undergone, and how they handle any privacy incidents or breaches. Based on this information, you can identify any weaknesses or gaps in the vendor's privacy protections and recommend or require any improvements or corrections before the app is deployed.Reference: IAPP CIPM Study Guide, page 82; ISO/IEC 27002:2013, section 15.1.2

This answer is not typically a function of a Privacy Officer, as it is usually performed by a separate role or department that is responsible for the technical aspects of data protection, such as the Chief Information Security Officer (CISO) or the Information Security Manager. A Privacy Officer is more focused on the legal, regulatory and ethical aspects of data protection, such as ensuring compliance with privacy laws and regulations, developing and implementing privacy policies and procedures, conducting privacy impact assessments and audits, providing privacy training and awareness, and handling privacy incidents or breaches.

This answer is the main reason to begin with 3-5 key metrics during the program development process, as it can help to align the privacy program with the organization's vision, mission and goals, and to measure the progress and performance of the program against these objectives. Key metrics are indicators that reflect the most important or critical aspects of the privacy program, such as compliance, risk, maturity, effectiveness or value. By starting with a small number of key metrics, the program development process can avoid being overwhelmed or distracted by too many or irrelevant data points, and can prioritize and concentrate on the areas that matter most for the organization.

This answer is the main purpose of a privacy program audit, as it can help to verify that the organization's data protection procedures are consistent and compliant with the applicable laws, regulations, standards and best practices, as well as with the organization's own policies and objectives. A privacy program audit is a systematic and independent examination of the organization's privacy program records, activities and performance against established criteria. A privacy program audit can also help to identify any gaps, weaknesses or risks in the data protection procedures, and to recommend or implement any improvements or corrective actions.

This answer is one of the situations when a data subject would have the right to require the erasure of his or her data without undue delay under the General Data Protection Regulation (GDPR), which is also known as the right to be forgotten or the right to erasure. This right allows a data subject to request that a data controller deletes his or her personal data when one of the following grounds applies:

The data is no longer necessary for its original purpose.

The data subject withdraws his or her consent for processing.

The data subject objects to processing based on legitimate interests or direct marketing.

The processing is unlawful or violates other laws or regulations.

The processing is related to online services offered to children.

This answer is the key factor that lays the foundation for all other elements of a privacy program, as it can help to establish leadership, accountability and support for the privacy program within the organization. A responsible internal stakeholder is a person or group who has authority, influence or interest in the organization's data processing activities, such as senior management, board members, business units or departments. A responsible internal stakeholder can help to define and communicate the organization's vision, mission and goals for privacy protection, allocate resources and budget for the privacy program, approve and endorse privacy policies and procedures, monitor and evaluate privacy program performance and compliance, and resolve any issues or conflicts that may arise from data processing activities.

The most appropriate law for Albert to mention at the interview as a priority concern for the privacy team is the Health Insurance Portability and Accountability Act (HIPAA). HIPAA is a US federal law that establishes national standards for the protection of sensitive patient health information. HIPAA regulates the use, disclosure, and safeguarding of protected health information (PHI), which is any information that can identify a patient or relate to their health or health care services. HIPAA applies to covered entities, such as health plans, health care providers, and health care clearinghouses, and their business associates, such as vendors, contractors, or partners that access or handle PHI on their behalf. HIPAA requires covered entities and business associates to comply with the Privacy Rule, which sets forth the rights of individuals and the obligations of entities regarding PHI; the Security Rule, which specifies the administrative, technical, and physical safeguards to ensure the confidentiality, integrity, and availability of PHI; and the Breach Notification Rule, which requires the notification of individuals, HHS, and in some cases the media, in the event of a breach of unsecured PHI.

Since Treasure Box intends to acquire a medical supply company in the coming weeks, it is likely that it will become a business associate of some covered entities under HIPAA. Therefore, it will need to ensure that its privacy program is compliant with HIPAA requirements and that it has appropriate agreements and safeguards in place to protect PHI. Albert should mention this as a priority concern for the privacy team and demonstrate his awareness and knowledge of HIPAA.

The other options are not as relevant or important as HIPAA for Treasure Box's new initiatives. The Gramm-Leach-Bliley Act (GLBA) is a US federal law that requires financial institutions to explain how they share and protect their customers' non-public personal information. It also repealed the Glass-Steagall Act of 1933, which prohibited commercial banks from offering investment and insurance services. GLBA does not apply to Treasure Box since it is not a financial institution. The General Data Protection Regulation (GDPR) is an EU law that provides a comprehensive framework for the protection of personal data of individuals in the EU. It imposes strict obligations and rights on data controllers and processors regarding the collection, use, disclosure, and security of personal data. GDPR does not apply to Treasure Box since it has recently decided to limit its shipments to customers in the 48 contiguous states of the US. The Telephone Consumer Protection Act (TCPA) is a US federal law that restricts telemarketing calls, text messages, faxes, and prerecorded messages. It requires prior express consent from consumers before making such communications and provides consumers with the right to opt out or revoke their consent. TCPA may apply to Treasure Box since it engages in direct phone marketing, but it is not a new initiative or a priority concern for the privacy team.Reference:HIPAA;GLBA;GDPR; [TCPA]

The topic that Albert most likely needs additional knowledge on is the necessary maturity level of privacy programs. Albert thinks that the AICPA/CICA Privacy Maturity Model (PMM) is a useful way to measure Treasure Box's ability to protect personal data, and that the company should aim to meet the highest level of maturity of this model. However, Albert may not realize that the PMM is not a prescriptive or definitive standard for privacy programs, but rather a descriptive and flexible tool for self-assessment and improvement. The PMM does not require or expect organizations to achieve the highest level of maturity for all privacy practices, as this may not be feasible, realistic, or appropriate for their specific context, objectives, and risks. The PMM recognizes that different levels of maturity may be suitable for different organizations or different aspects of their privacy programs, depending on their needs and circumstances. Therefore, Albert should not assume that the highest level of maturity is always the best or the most rigorous option for privacy protection. Albert should learn more about how to use the PMM effectively and appropriately, and how to determine the optimal level of maturity for Treasure Box's privacy program.

The other options are not topics that Albert most likely needs additional knowledge on. Albert seems to have a good understanding of the role of privacy in retail companies, as he is aware of the importance of protecting customer and employee personal data, as well as complying with relevant laws and regulations. Albert also seems to have a good understanding of the possibility of delegating responsibilities related to privacy, as he plans to assist the company with meeting its privacy obligations and goals. Albert also seems to have a good understanding of the requirements for a managerial position with privacy protection duties, as he intends to demonstrate his knowledge, skills, and experience in this area during his interview.Reference:[AICPA/CICA Privacy Maturity Model]; [Privacy Maturity Model: How Mature Is Your Privacy Program?]