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Question 112 - CIPM discussion

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SCENARIO

Please use the following to answer the next QUESTION:

Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space's practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.

Penny's colleague in Marketing is excited by the new sales and the company's plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her ''I heard someone in the breakroom talking about some new privacy laws but I really don't think it affects us. We're just a small company. I mean we just sell accessories online, so what's the real risk?'' He has also told her that he works with a number of small companies that help him get projects completed in a hurry. ''We've got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don't have.''

In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny's colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team ''didn't know what to do or who should do what. We hadn't been trained on it but we're a small team though, so it worked out OK in the end.'' Penny is concerned that these issues will compromise Ace Space's privacy and data protection.

Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data ''shake up''. Her mission is to cultivate a strong privacy culture within the company.

Penny has a meeting with Ace Space's CEO today and has been asked to give her first impressions and an overview of her next steps.

What is the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has?

A.

Analyze the data inventory to map data flows

Answers
A.

Analyze the data inventory to map data flows

B.

Audit all vendors' privacy practices and safeguards

Answers
B.

Audit all vendors' privacy practices and safeguards

C.

Conduct a Privacy Impact Assessment for the company

Answers
C.

Conduct a Privacy Impact Assessment for the company

D.

Review all cloud contracts to identify the location of data servers used

Answers
D.

Review all cloud contracts to identify the location of data servers used

Suggested answer: A

Explanation:

The best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has is to analyze the data inventory to map data flows. A data inventory is a comprehensive record of the personal data that an organization collects, stores, uses and shares. It helps to identify the sources, categories, locations, recipients and retention periods of personal data. A data flow map is a visual representation of how personal data flows within and outside an organization. It helps to identify the data transfers, processing activities, legal bases, risks and safeguards of personal data.

By analyzing the data inventory and mapping the data flows, Penny can gain a clear picture of the personal data lifecycle at Ace Space and identify any gaps or issues that need to be addressed. For example, she can determine whether Ace Space has a lawful basis for processing personal data of EU customers, whether it has adequate security measures to protect personal data from unauthorized access or loss, whether it has appropriate contracts with its vendors and cloud providers to ensure compliance with applicable laws and regulations, and whether it has mechanisms to respect the rights and preferences of its customers.

The other options are not the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has. Auditing all vendors' privacy practices and safeguards (B) is an important step to ensure that Ace Space's third-party processors are complying with their contractual obligations and legal requirements, but it does not provide a comprehensive overview of Ace Space's own personal data processing activities. Conducting a Privacy Impact Assessment (PIA) for the company is a useful tool to assess the privacy risks and impacts of a specific project or initiative involving personal data, but it does not provide a baseline understanding of the existing personal data landscape at Ace Space. Reviewing all cloud contracts to identify the location of data servers used (D) is a relevant aspect of understanding the location of personal data, but it does not cover other aspects such as classification and processing purpose.

CIPM Body of Knowledge Domain I: Privacy Program Governance - Task 1: Establish privacy program vision and strategy - Subtask 1: Identify applicable privacy laws, regulations and standards

CIPM Body of Knowledge Domain II: Privacy Program Operational Life Cycle - Task 1: Assess current state of privacy in an organization - Subtask 1: Conduct gap analysis

CIPM Study Guide - Chapter 2: Privacy Program Governance - Section 2.1: Data Inventory

CIPM Study Guide - Chapter 2: Privacy Program Governance - Section 2.2: Data Flow Mapping

asked 22/11/2024
Chan Sai Yu
43 questions
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