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• India - 12,42,327 INR

 

NEW QUESTION # 49
Which of the following helps build trust with customers and stakeholders?

• A. Enable customers to view and change their own personal information within a dedicated portal.
• B. Only publish what is legally necessary to reduce your liability.
• C. Publish your privacy policy using broad language to ensure all of your organization's activities are captured.
• D. Provide a dedicated privacy space with the privacy policy, explanatory documents and operation frameworks.

Answer: D

Explanation:
Explanation
Providing a dedicated privacy space with the privacy policy, explanatory documents and operation frameworks helps build trust with customers and stakeholders. A dedicated privacy space is a section on an organization's website or app that provides clear and transparent information about how the organization processes personal information and respects data subject rights. It can include documents such as: a privacy policy that explains what personal information is collected, why it is collected, how it is used, who it is shared with, and how it is protected; explanatory documents that provide more details or examples of specific processing activities or scenarios; and operation frameworks that describe the procedures and mechanisms for data subject requests, complaints, inquiries, or feedback. A dedicated privacy space can help customers and stakeholders understand the organization's privacy practices, choices, and values, and enhance their confidence and trust.
References:
* CIPM Body of Knowledge (2021), Domain II: Privacy Program Framework, Section A: Privacy Program Framework Components, Subsection 1: Privacy Policies
* CIPM Study Guide (2021), Chapter 4: Privacy Program Framework Components, Section 4.1: Privacy Policies
* CIPM Textbook (2019), Chapter 4: Privacy Program Framework Components, Section 4.1: Privacy Policies
* CIPM Practice Exam (2021), Question 140

NEW QUESTION # 50
SCENARIO
Please use the following to answer the next QUESTION:
Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green energy market. The current line of products includes wind turbines, solar energy panels, and equipment for geothermal systems. A talented team of developers means that NatGen's line of products will only continue to grow.
With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help manage the company's growth. One recent suggestion has been to combine the legal and security functions of the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in ways that will best suit their needs. She does not want administrative oversight and complex structuring to get in the way of people doing innovative work.
Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use the best possible equipment for electronic storage of customer and employee data. She simply needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before the company gets to that stage.
Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can adjust the company privacy policy according to what works best for their particular departments. NatGen's CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of normal business activities.
Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because the employees need no special preparation. They will simply have to document any concerns they hear.
Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique approach.
What is the most likely reason the Chief Information Officer (CIO) believes that generating a list of needed IT equipment is NOT adequate?

• A. Senior staff members need to first commit to adopting a minimum number of Privacy Enhancing Technologies (PETs).
• B. Staff members across departments need time to review technical information concerning any new databases.
• C. The company needs to have policies and procedures in place to guide the purchasing decisions.
• D. The privacy notice for customers and the Business Continuity Plan (BCP) still need to be reviewed.

Answer: C

NEW QUESTION # 51
SCENARIO
Please use the following to answer the next QUESTION:
Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments.
After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.
The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.
Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.
In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the product. This data is all stored in the cloud and is encrypted both during transmission and at rest.
Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.
What step in the system development process did Manasa skip?

• A. Work with Sanjay to review any necessary privacy requirements to be built into the product.
• B. Build the artificial intelligence feature so that users would not have to input sensitive information into the Handy Helper.
• C. Certify that the Handy Helper meets the requirements of the EU-US Privacy Shield Framework.
• D. Obtain express written consent from users of the Handy Helper regarding marketing.

Answer: C

NEW QUESTION # 52
When devising effective employee policies to address a particular issue, which of the following should be included in the first draft?

• A. Rationale for the policy.
• B. Explanation of how the policy is applied within the organization.
• C. Roles and responsibilities of the different groups of individuals.
• D. Points of contact for the employee.

Answer: D

NEW QUESTION # 53
SCENARIO
Please use the following to answer the next QUESTION:
As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.
You are left contemplating:
What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success?
What are the next action steps?
What process could most effectively be used to add privacy protections to a new, comprehensive program being developed at Consolidated?

• A. Information Security Planning.
• B. Innovation Privacy Standards.
• C. Privacy by Design.
• D. Privacy Step Assessment.

Answer: C

Explanation:
This is a process that embeds privacy protections into the design and development of new technologies, systems, products or services that involve personal data. It ensures that privacy is considered at every stage of the development process, from conception to completion, and that the privacy principles are integrated into the core functionality of the program.

NEW QUESTION # 54
SCENARIO
Please use the following to answer the next QUESTION:
As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.
You are left contemplating:
What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success?
What are the next action steps?
What analytic can be used to track the financial viability of the program as it develops?

• A. Gap analysis.
• B. Cost basis.
• C. Return to investment.
• D. Breach impact modeling.

Answer: C

Explanation:
This analytic can be used to track the financial viability of the program as it develops, as it measures the net benefit of the program compared to its cost. It can show how much value the program adds to the organization by preventing or reducing data breaches, fines, lawsuits, reputational damage and other potential costs.

NEW QUESTION # 55
Which of the following is a physical control that can limit privacy risk?

• A. Encryption.
• B. Tokenization.
• C. Keypad or biometric access.
• D. user access reviews.

Answer: C

Explanation:
Explanation
A physical control that can limit privacy risk is keypad or biometric access. This is a type of access control that restricts who can enter or access a physical location or device where personal data is stored or processed.
Keypad or biometric access requires a code or a biological feature (such as a fingerprint or a face scan) to authenticate the identity and authorization of the person seeking access. This can prevent unauthorized access, theft, loss, or damage of personal data by outsiders or insiders, . References: [CIPM - International Association of Privacy Professionals], [Free CIPM Study Guide - International Association of Privacy Professionals]

NEW QUESTION # 56
SCENARIO
Please use the following to answer the next question:
Liam is the newly appointed information technology (IT) compliance manager at Mesa, a USbased outdoor clothing brand with a global E-commerce presence. During his second week, he is contacted by the company' s IT audit manager, who informs him that the auditing team will be conducting a review of Mesa's privacy compliance risk in a month.
A bit nervous about the audit, Liam asks his boss what his predecessor had completed related to privacy compliance before leaving the company. Liam is told that a consent management tool had been added to the website and they commissioned a privacy risk evaluation from a small consulting firm last year that determined that their risk exposure was relatively low given their current control environment. After reading the consultant's report, Liam realized that the scope of the assessment was limited to breach notification laws in the US and the Payment Card Industry's Data Security Standard (PCI DSS).
Not wanting to let down his new team, Liam kept his concerns about the report to himself and figured he could try to put some additional controls into place before the audit. Having some privacy compliance experience in his last role, Liam thought he might start by having discussions with the E-commerce and marketing teams.
The E-commerce Director informed him that they were still using the cookie consent tool forcibly placed on the home screen by the CIO, but could not understand the point since their office was not located in California or Europe. The marketing director touted his department's success with purchasing email lists and taking a shotgun approach to direct marketing. Both directors highlighted their tracking tools on the website to enhance customer experience while learning more about where else the customer had shopped. The more people Liam met with, the more it became apparent that privacy awareness and the general control environment at Mesa needed help.
With three weeks before the audit, Liam updated Mesa's Privacy Notice himself, which was taken and revised from a competitor's website. He also wrote policies and procedures outlining the roles and responsibilities for privacy within Mesa and distributed the document to all departments he knew of with access to personal information.
During this time. Liam also filled the backlog of data subject requests for deletion that had been sent to him by the customer service manager. Liam worked with application owners to remove these individual's information and order history from the customer relationship management (CRM) tool, the enterprise resource planning (ERP). the data warehouse and the email server.
At the audit kick-off meeting. Liam explained to his boss and her team that there may still be some room for improvement, but he thought the risk had been mitigated to an appropriate level based on the work he had done thus far.
After the audit had been completed, the audit manager and Liam met to discuss her team's findings, and much to his dismay. Liam was told that none of the work he had completed prior to the audit followed best practices for governance and risk mitigation. In fact, his actions only opened the company up to additional risk and scrutiny. Based on these findings. Liam worked with external counsel and an established privacy consultant to develop a remediation plan.
Why do Mesa's E-commerce and marketing efforts need to be compliant with the GDPR?

• A. Mesa uses mailing lists and engages in direct marketing.
• B. Mesa is US-based.
• C. Mesa has a global E-commerce presence and may have customers in Europe.
• D. Mesa uses automated systems and tools to process personal data.

Answer: C

NEW QUESTION # 57
SCENARIO
Please use the following to answer the next QUESTION:
Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green energy market. The current line of products includes wind turbines, solar energy panels, and equipment for geothermal systems. A talented team of developers means that NatGen's line of products will only continue to grow.
With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help manage the company's growth. One recent suggestion has been to combine the legal and security functions of the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in ways that will best suit their needs. She does not want administrative oversight and complex structuring to get in the way of people doing innovative work.
Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use the best possible equipment for electronic storage of customer and employee data. She simply needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before the company gets to that stage.
Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can adjust the company privacy policy according to what works best for their particular departments.
NatGen's CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of normal business activities.
Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because the employees need no special preparation. They will simply have to document any concerns they hear.
Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique approach.
What is the most likely reason the Chief Information Officer (CIO) believes that generating a list of needed IT equipment is NOT adequate?

• A. Senior staff members need to first commit to adopting a minimum number of Privacy Enhancing Technologies (PETs).
• B. Staff members across departments need time to review technical information concerning any new databases.
• C. The company needs to have policies and procedures in place to guide the purchasing decisions.
• D. The privacy notice for customers and the Business Continuity Plan (BCP) still need to be reviewed.

Answer: C

Explanation:
The most likely reason the Chief Information Officer (CIO) believes that generating a list of needed IT equipment is not adequate is that the company needs to have policies and procedures in place to guide the purchasing decisions. Policies and procedures are essential for ensuring that the IT equipment meets the business needs and objectives, as well as the legal and regulatory requirements for data protection and security6 Policies and procedures can help the company to:
* Define the roles and responsibilities of the IT staff and other stakeholders involved in the purchasing process.
* Establish the criteria and standards for selecting and evaluating the IT equipment vendors and products.
* Determine the budget and timeline for acquiring and deploying the IT equipment.
* Implement the best practices for installing, configuring, testing, maintaining, and disposing of the IT equipment.
* Monitor and measure the performance and effectiveness of the IT equipment.
Without policies and procedures in place, the company may face risks such as:
* Wasting time and money on unnecessary or inappropriate IT equipment.
* Exposing sensitive data to unauthorized access or loss due to inadequate or incompatible IT equipment.
* Failing to comply with data protection laws or industry standards due to non-compliant or outdated IT equipment.
* Facing legal or reputational consequences due to data breaches or incidents caused by faulty or insecure IT equipment.
Therefore, generating a list of needed IT equipment is not adequate without having policies and procedures in place to guide the purchasing decisions. References: 6: IT Policies & Procedures: A Quick Guide - ProjectManager; 7: IT Policies & Procedures: A Quick Guide - ProjectManager

NEW QUESTION # 58
Which of the following is an example of Privacy by Design (PbD)?

• A. The human resources group develops a training program from employees to become certified in privacy policy.
• B. A company hires a professional to structure a privacy program that anticipates the increasing demands of new laws.
• C. The information technology group uses privacy considerations to inform the development of new networking software.
• D. A labor union insists that the details of employers' data protection methods be documented in a new contract.

Answer: D

NEW QUESTION # 59
In a mobile app for purchasing and selling concert tickets, users are prompted to create a personalized profile prior to engaging in transactions. Once registered, users can securely access their profiles within the app, empowering them to manage and modify personal data as needed.
Which foundational Privacy by Design (PbD) principle does this feature follow?

• A. Full functionality - positive-sum, not zero-sum.
• B. End-to-end security - full life cycle protection.
• C. Proactive, not reactive; preventative, not remedial.
• D. Respect for user privacy - keep it user-centric.

Answer: D

Explanation:
Comprehensive and Detailed Explanation:
This scenario follows the Privacy by Design (PbD) principle of "Respect for User Privacy - Keep it User-Centric" because it gives users direct control over their personal data, allowing them to access, modify, and manage their information.
Option A (Proactive, not reactive; preventative, not remedial) emphasizes anticipating privacy risks before they arise, which is not the focus of this feature.
Option B (Full functionality - positive-sum, not zero-sum) refers to integrating privacy protections without sacrificing usability or security.
Option D (End-to-end security - full life cycle protection) relates to safeguarding data throughout its entire life cycle, which is not the main principle demonstrated in this scenario.
Reference:
CIPM Official Textbook, Module: Privacy by Design (PbD) and Privacy Engineering - Section on User Control and Transparency Principles.

NEW QUESTION # 60
SCENARIO
Please use the following to answer the next quetion:
Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green energy market. The current line of products includes wind turbines, solar energy panels, and equipment for geothermal systems. A talented team of developers means that NatGen's line of products will only continue to grow.
With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help manage the company's growth. One recent suggestion has been to combine the legal and security functions of the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in ways that will best suit their needs. She does not want administrative oversight and complex structuring to get in the way of people doing innovative work.
Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use the best possible equipment for electronic storage of customer and employee data. She simply needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before the company gets to that stage.
Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can adjust the company privacy policy according to what works best for their particular departments.
NatGen's CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of normal business activities.
Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because the employees need no special preparation. They will simply have to document any concerns they hear.
Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique approach.
What Data Lifecycle Management (DLM) principle should the company follow if they end up allowing departments to interpret the privacy policy differently?

• A. Arrange for official credentials for staff members.
• B. Create categories to reflect degrees of data importance.
• C. Adequately document reasons for inconsistencies.
• D. Prove the authenticity of the company's records.

Answer: C

Explanation:
If the company ends up allowing departments to interpret the privacy policy differently, they should follow the Data Lifecycle Management (DLM) principle of adequately documenting reasons for inconsistencies. This principle requires that data should be accurate, complete, and consistent throughout its lifecycle and that any deviations or discrepancies should be justified and recorded1 This would help the company to maintain data quality and integrity, as well as to demonstrate accountability and compliance with data protection regulations2 The other options are not DLM principles that the company should follow if they allow departments to interpret the privacy policy differently. Proving the authenticity of the company's records is a principle related to data preservation and archiving, not data interpretation3 Arranging for official credentials for staff members is a principle related to data access and security, not data interpretation4 Creating categories to reflect degrees of data importance is a principle related to data classification and retention, not data interpretation5 References: 1: Data Lifecycle Management: A Complete Guide | Splunk; 2: Data Lifecycle Management | IBM; 3: Data Preservation | Digital Preservation Handbook; 4: Data Access Management Best Practices | Smartsheet; 5: Data Classification: What It Is And How To Do It | Varonis

NEW QUESTION # 61
SCENARIO
Please use the following to answer the next QUESTION:
John is the new privacy officer at the prestigious international law firm - A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe.
During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor - MessageSafe. Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.
John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.
At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime.
Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution.
Furthermore, the off- premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.
Which of the following is a TRUE statement about the relationship among the organizations?

• A. A&M LLP's service contract must be amended to list Cloud Inc. as a sub-processor.
• B. Cloud Inc. must notify A&M LLP of a data breach immediately.
• C. Cloud Inc. should enter into a data processor agreement with A&M LLP.
• D. MessageSafe is liable if Cloud Inc. fails to protect data from A&M LLP.

Answer: B

NEW QUESTION # 62
Which of the following is NOT a type of privacy program metric?

• A. Value creation metrics.
• B. Data enhancement metrics.
• C. Business enablement metrics.
• D. Risk-reduction metrics.

Answer: B

Explanation:
Data enhancement metrics are not a type of privacy program metric because they do not measure the performance, value, or risk of the privacy program. Data enhancement metrics are related to the quality, accuracy, and completeness of the data collected and processed by the organization, which are not directly linked to the privacy program objectives. References: CIPM Body of Knowledge, Domain II: Privacy Program Governance, Section B: Establishing a Privacy Program Framework, Subsection 2: Privacy Program Metrics.

NEW QUESTION # 63
SCENARIO
Please use the following to answer the next QUESTION:
Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.
Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal data. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.
Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following day, to get insight into how the office computer system is currently set-up and managed.
Richard needs to closely monitor the vendor in charge of creating the firm's database mainly because of what?

• A. The vendor will be in direct contact with all of the law firm's personal data.
• B. The vendor will be required to report any privacy violations to the appropriate authorities.
• C. The vendor may not be aware of the privacy implications involved in the project.
• D. The vendor may not be forthcoming about the vulnerabilities of the database.

Answer: A

Explanation:
Explanation
The main reason why Richard needs to closely monitor the vendor in charge of creating the firm's database is that the vendor will be in direct contact with all of the law firm's personal data. This means that the vendor will have access to sensitive and confidential information about the law firm's clients, such as their financial and medical data, which could expose them to identity theft, fraud, or other harms if mishandled or breached.
Therefore, Richard needs to ensure that the vendor follows the best practices of data protection and security, such as:
* Signing a data processing agreement that specifies the scope, purpose, duration, and terms of the data processing activities, as well as the rights and obligations of both parties.
* Implementing appropriate technical and organizational measures to protect the data from unauthorized or unlawful access, use, disclosure, alteration, or destruction, such as encryption, access control, backup and recovery, logging and monitoring, etc.
* Complying with the relevant laws and regulations that govern the collection, use, transfer, and retention of personal data, such as the GDPR or other local privacy laws.
* Reporting any data breaches or incidents to the law firm and the relevant authorities as soon as possible and taking corrective actions to mitigate the impact and prevent recurrence.
* Deleting or returning the data to the law firm after the completion of the project or upon request.

NEW QUESTION # 64
SCENARIO
Please use the following to answer the next QUESTION:
Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.
The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.
Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.
In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the product. This data is all stored in the cloud and is encrypted both during transmission and at rest.
Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eurek a. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.
What step in the system development process did Manasa skip?

• A. Work with Sanjay to review any necessary privacy requirements to be built into the product.
• B. Build the artificial intelligence feature so that users would not have to input sensitive information into the Handy Helper.
• C. Certify that the Handy Helper meets the requirements of the EU-US Privacy Shield Framework.
• D. Obtain express written consent from users of the Handy Helper regarding marketing.

Answer: C

NEW QUESTION # 65
SCENARIO
Please use the following to answer the next question:
As the director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient
"buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.
You are left contemplating: What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success? What are the next action steps?
What practice would afford the Director the most rigorous way to check on the program's compliance with laws, regulations and industry best practices?

• A. Auditing
• B. Assessment
• C. Monitoring
• D. Forensics

Answer: C

NEW QUESTION # 66
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The CIPM certification is recognized by businesses and organizations around the world as a mark of excellence in privacy management. It demonstrates to employers and clients that the holder has the knowledge and skills necessary to manage and protect sensitive data and ensure compliance with privacy regulations. It also provides a competitive advantage in the job market, as employers increasingly seek out candidates with privacy management expertise.

 

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