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IAPP Certified Information Privacy Manager (CIPM) Sample Questions (Q45-Q50):
NEW QUESTION # 45
SCENARIO
Please use the following to answer the next QUESTION:
It's just what you were afraid of. Without consulting you, the information technology director at your organization launched a new initiative to encourage employees to use personal devices for conducting business. The initiative made purchasing a new, high-specification laptop computer an attractive option, with discounted laptops paid for as a payroll deduction spread over a year of paychecks. The organization is also paying the sales taxes. It's a great deal, and after a month, more than half the organization's employees have signed on and acquired new laptops. Walking through the facility, you see them happily customizing and comparing notes on their new computers, and at the end of the day, most take their laptops with them, potentially carrying personal data to their homes or other unknown locations. It's enough to give you data- protection nightmares, and you've pointed out to the information technology Director and many others in the organization the potential hazards of this new practice, including the inevitability of eventual data loss or theft.
Today you have in your office a representative of the organization's marketing department who shares with you, reluctantly, a story with potentially serious consequences. The night before, straight from work, with laptop in hand, he went to the Bull and Horn Pub to play billiards with his friends. A fine night of sport and socializing began, with the laptop "safely" tucked on a bench, beneath his jacket. Later that night, when it was time to depart, he retrieved the jacket, but the laptop was gone. It was not beneath the bench or on another bench nearby. The waitstaff had not seen it. His friends were not playing a joke on him. After a sleepless night, he confirmed it this morning, stopping by the pub to talk to the cleanup crew. They had not found it. The laptop was missing. Stolen, it seems. He looks at you, embarrassed and upset.
You ask him if the laptop contains any personal data from clients, and, sadly, he nods his head, yes. He believes it contains files on about 100 clients, including names, addresses and governmental identification numbers. He sighs and places his head in his hands in despair.
In order to determine the best course of action, how should this incident most productively be viewed?
- A. As the premeditated theft of company data, until shown otherwise.
- B. As a potential compromise of personal information through unauthorized access.
- C. As an incident that requires the abrupt initiation of a notification campaign.
- D. As the accidental loss of personal property containing data that must be restored.
Answer: B
Explanation:
Explanation
This answer recognizes the risk of data breach that may result from the loss of the laptop, as it may expose the personal information of the clients to unauthorized or unlawful processing. A data breach is defined as a security incident that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed. A data breach may have serious consequences for the individuals whose data is compromised, such as identity theft, fraud, discrimination, financial loss or reputational damage. Therefore, it is important to view this incident as a potential compromise of personal information and take appropriate measures to contain, assess and mitigate the impact of the breach. References: IAPP CIPM Study Guide, page 86; ISO/IEC 27002:2013, section 16.1.1
NEW QUESTION # 46
SCENARIO
Please use the following to answer the next QUESTION:
As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically Questionable practices, including unauthorized sales of personal data to marketers. Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that "appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.
Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures.
He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.
You give a presentation to your CEO about privacy program maturity. What does it mean to have a "managed" privacy program, according to the AICPA/CICA Privacy Maturity Model?
- A. Reviews are conducted to assess the effectiveness of the controls in place.
- B. Procedures or processes exist, however they are not fully documented and do not cover all relevant aspects.
- C. Procedures and processes are fully documented and implemented, and cover all relevant aspects.
- D. Regular review and feedback are used to ensure continuous improvement toward optimization of the given process.
Answer: C
Explanation:
This answer is the best way to describe what it means to have a "managed" privacy program, according to the AICPA/CICA Privacy Maturity Model (PMM), which is a framework that measures the effectiveness and maturity of an organization's privacy program based on five phases: ad hoc, repeatable, defined, managed and optimized. The managed phase is the fourth level of maturity in the PMM, which indicates that the organization has a formal and consistent approach to privacy protection and that its privacy practices are aligned with its policies and objectives. The managed phase means that the organization has procedures and processes that are fully documented and implemented, and cover all relevant aspects of data collection, use, storage, protection, sharing and disposal. The managed phase also means that the organization has controls and measures that are monitored and evaluated regularly, and that any issues or incidents are reported and resolved promptly.
NEW QUESTION # 47
Which of the following best demonstrates the effectiveness of a firm's privacy incident response process?
- A. The decrease of mean time to resolve privacy incidents
- B. The increase of privacy incidents reported by users
- C. The decrease of security breaches
- D. The decrease of notifiable breaches
Answer: A
NEW QUESTION # 48
SCENARIO
Please use the following to answer the next QUESTION:
Paul Daniels, with years of experience as a CEO, is worried about his son Carlton's successful venture, Gadgo. A technological innovator in the communication industry that quickly became profitable, Gadgo has moved beyond its startup phase. While it has retained its vibrant energy, Paul fears that under Carlton's direction, the company may not be taking its risks or obligations as seriously as it needs to. Paul has hired you, a Privacy Consultant, to assess the company and report to both father and son. "Carlton won't listen to me," Paul says, "but he may pay attention to an expert." Gadgo's workplace is a clubhouse for innovation, with games, toys, snacks. espresso machines, giant fish tanks and even an iguana who regards you with little interest. Carlton, too, seems bored as he describes to you the company's procedures and technologies for data protection. It's a loose assemblage of controls, lacking consistency and with plenty of weaknesses. "This is a technology company," Carlton says. "We create. We innovate. I don't want unnecessary measures that will only slow people down and clutter their thoughts." The meeting lasts until early evening. Upon leaving, you walk through the office it looks as if a strong windstorm has recently blown through, with papers scattered across desks and tables and even the floor. A
"cleaning crew" of one teenager is emptying the trash bins. A few computers have been left on for the night, others are missing. Carlton takes note of your attention to this: "Most of my people take their laptops home with them, or use their own tablets or phones. I want them to use whatever helps them to think and be ready day or night for that great insight. It may only come once!" What would be the best kind of audit to recommend for Gadgo?
- A. A third-party audit.
- B. A self-certification.
- C. An internal audit.
- D. A supplier audit.
Answer: A
Explanation:
This answer is the best kind of audit to recommend for Gadgo, as it can provide an independent and objective assessment of the company's privacy program and practices, as well as identify any gaps, weaknesses or risks that need to be addressed or improved. A third-party audit is conducted by an external auditor who has the necessary expertise, experience and credentials to evaluate the company's compliance with the applicable laws, regulations, standards and best practices for data protection. A third-party audit can also help to enhance the company's reputation and trust among its customers, partners and stakeholders, as well as demonstrate its commitment and accountability for privacy protection. References: IAPP CIPM Study Guide, page 881; ISO
/IEC 27002:2013, section 18.2.1
NEW QUESTION # 49
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 the most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP?
- A. MessageSafe must flow-down its data protection contract terms with A&M LLP to Cloud Inc.
- B. MessageSafe must apply appropriate security controls on the cloud infrastructure.
- C. MessageSafe must apply due diligence before trusting Cloud Inc. with the personal data received from A&M LLP.
- D. MessageSafe must notify A&M LLP of a data breach.
Answer: B
Explanation:
The most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP is to require MessageSafe to apply appropriate security controls on the cloud infrastructure. This control ensures that MessageSafe takes responsibility for securing the personal data that it processes on behalf of A&M LLP on the cloud platform provided by Cloud Inc. According to the GDPR, data processors must implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing personal data1 These measures may include encryption, pseudonymisation, access control, backup and recovery, logging and monitoring, vulnerability management, incident response, etc2 Furthermore, data processors must ensure that any sub-processors they engage to process personal data on behalf of the data controller also comply with the same obligations3 Therefore, MessageSafe must ensure that Cloud Inc. provides adequate security guarantees for the cloud infrastructure and services that it uses to host the email continuity service for A&M LLP. MessageSafe must also monitor and audit the security performance of Cloud Inc. and report any issues or breaches to A&M LLP. References: 1: Article 32 GDPR | General Data Protection Regulation (GDPR); 2: Guidelines 4/2019 on Article 25 Data Protection by Design and by Default | European Data Protection Board; 3: Article 28 GDPR | General Data Protection Regulation (GDPR)
NEW QUESTION # 50
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