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NEW QUESTION # 80
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.
As Richard begins to research more about Data Lifecycle Management (DLM), he discovers that the law office can lower the risk of a data breach by doing what?
- A. Increasing the number of experienced staff to code and categorize the incoming data.
- B. Minimizing the time it takes to retrieve the sensitive data.
- C. Reducing the volume and the type of data that is stored in its system.
- D. Prioritizing the data by order of importance.
Answer: C
NEW QUESTION # 81
A Human Resources director at a company reported that a laptop containing employee payroll data was lost on the train. Which action should the company take IMMEDIATELY?
- A. Report the theft to the senior management
- B. Wipe the hard drive remotely
- C. Report the theft to law enforcement
- D. Perform a multi-factor risk analysis
Answer: D
NEW QUESTION # 82
Which of the following controls does the PCI DSS framework NOT require?
- A. Maintain a vulnerability management program.
- B. Implement strong asset control protocols.
- C. Implement strong access control measures.
- D. Maintain an information security policy.
Answer: B
Explanation:
Explanation
The PCI DSS framework does not require implementing strong asset control protocols. Asset control protocols are policies and procedures that govern how an organization manages its physical and digital assets, such as inventory, equipment, software, data, etc. Asset control protocols may include aspects such as identification, classification, valuation, tracking, maintenance, disposal, etc. Asset control protocols are important for ensuring the security and integrity of an organization's assets, but they are not part of the PCI DSS framework.
NEW QUESTION # 83
In regards to the collection of personal data conducted by an organization, what must the data subject be allowed to do?
- A. Challenge the authenticity of the personal data and have it corrected if needed
- B. Obtain a guarantee of prompt notification in instances involving unauthorized access of the data
- C. Evaluate the qualifications of a third-party processor before any data is transferred to that processor
- D. Set a time-limit as to how long the personal data may be stored by the organization
Answer: D
NEW QUESTION # 84
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 information will be LEAST crucial from a privacy perspective in Penny's review of vendor contracts?
- A. Liability for a data breach
- B. Pricing for data security protections
- C. Audit rights
- D. The data a vendor will have access to
Answer: B
NEW QUESTION # 85
Data retention and destruction policies should meet all of the following requirements EXCEPT?
- A. The organization should be documenting and reviewing policies of its other functions to ensure alignment (e.g. HR, business development, finance, etc.).
- B. Personal information should be retained only for as long as necessary to perform its stated purpose.
- C. Documentation related to audit controls (third-party or internal) should be saved in a non-permanent format by default.
- D. Data destruction triggers and methods should be documented.
Answer: C
NEW QUESTION # 86
Integrating privacy requirements into functional areas across the organization happens at which stage of the privacy operational life cycle?
- A. Assessing data.
- B. Protecting personal data.
- C. Sustaining program performance.
- D. Responding to requests and incidents.
Answer: B
Explanation:
Explanation
Integrating privacy requirements into functional areas across the organization happens at the "protect" stage of the privacy operational life cycle. This stage involves implementing privacy policies, procedures, and controls to ensure that personal data is processed in a lawful, fair, and transparent manner. The other stages of the privacy operational life cycle are "assess", "align", "respond", and "sustain". References: CIPM Body of Knowledge, Domain III: Privacy Program Operational Life Cycle, Section B: Protect.
NEW QUESTION # 87
Which of the following best describes proper compliance for an international organization using Binding Corporate Rules (BCRs) as a controller or processor?
- A. All employees must follow the privacy regulations of the jurisdictions where the current scope of their work is established.
- B. All employees are subject to the rules in their entirety, regardless of where the work is taking place.
- C. Employees must sign an ad hoc contractual agreement each time personal data is exported.
- D. Employees who control personal data must complete a rigorous certification procedure, as they are exempt from legal enforcement.
Answer: C
Explanation:
Explanation/Reference: https://www.lexology.com/library/detail.aspx?g=80239951-01b8-409f-9019-953f5233852e
NEW QUESTION # 88
What should a privacy professional keep in mind when selecting which metrics to collect?
- A. Metrics should reveal strategies for increasing company earnings.
- B. A variety of metrics should be collected before determining their specific functions.
- C. Metrics should be reported to the public.
- D. The number of metrics should be limited at first.
Answer: D
Explanation:
Explanation
A privacy professional should keep in mind that the number of metrics should be limited at first when selecting which metrics to collect. Metrics are quantitative measures that help evaluate the performance and effectiveness of a privacy program. However, collecting too many metrics can be overwhelming, confusing, and costly. Therefore, a privacy professional should start with a few key metrics that are relevant, meaningful, actionable, and aligned with the organization's privacy goals and priorities. These metrics can be refined and expanded over time as the privacy program matures and evolves. References: [Privacy Metrics], [Measuring Privacy Program Effectiveness]
NEW QUESTION # 89
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. Cloud Inc. must notify A&M LLP of a data breach immediately.
- B. Cloud Inc. should enter into a data processor agreement with A&M LLP.
- C. MessageSafe is liable if Cloud Inc. fails to protect data from A&M LLP.
- D. A&M LLP's service contract must be amended to list Cloud Inc. as a sub-processor.
Answer: A
NEW QUESTION # 90
What is the best way to understand the location, use and importance of personal data within an organization?
- A. By testing the security of data systems.
- B. By analyzing the data inventory.
- C. By evaluating methods for collecting data.
- D. By interviewing employees tasked with data entry.
Answer: C
Explanation:
Explanation
The best way to understand the location, use and importance of personal data within an organization is by evaluating methods for collecting data. This will help to identify the sources, purposes, and categories of data that the organization processes, as well as the data flows and transfers within and outside the organization. By doing so, the organization can assess the risks and opportunities associated with data processing and design appropriate privacy policies and controls. References: [IAPP CIPM Study Guide], page 29-30; [Data Inventory]
NEW QUESTION # 91
SCENARIO
Please use the following to answer the next QUESTION:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has found some degree of disorganization after touring the company headquarters. His uncle Henry had always focused on production - not data processing - and Anton is concerned. In several storage rooms, he has found paper files, disks, and old computers that appear to contain the personal data of current and former employees and customers. Anton knows that a single break-in could irrevocably damage the company's relationship with its loyal customers. He intends to set a goal of guaranteed zero loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the company. However, Kenneth - his uncle's vice president and longtime confidante - wants to hold off on Anton's idea in favor of converting any paper records held at the company to electronic storage. Kenneth believes this process would only take one or two years. Anton likes this idea; he envisions a password- protected system that only he and Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware store down the street will be responsible for their own information management. Then, any unneeded subsidiary data still in Anton's possession can be destroyed within the next few years.
After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers. Kenneth insists that two lost hard drives in Question are not cause for concern; all of the data was encrypted and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago, but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another trusted employee with a law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should be safe for another five years, at which time he can order another check.
Documentation of this analysis will show auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the effort is worth it. Anton wants his uncle's legacy to continue for many years to come.
Which of Anton's plans for improving the data management of the company is most unachievable?
- A. His initiative to achieve regulatory compliance.
- B. His intention to send notice letters to customers and employees.
- C. His objective for zero loss of personal information.
- D. His intention to transition to electronic storage.
Answer: C
Explanation:
Explanation
Anton's objective for zero loss of personal information is the most unachievable among his plans for improving the data management of the company. While this objective is admirable and desirable, it is unrealistic and impractical to guarantee that no personal information will ever be lost due to a data breach or incident. Data breaches are inevitable and unpredictable events that can affect any organization regardless of its size or industry4 Even with the best data security practices and tools in place, there is always a possibility of human error, system failure, malicious attack, or natural disaster that could compromise personal information5 Therefore, Anton should focus on minimizing the likelihood and impact of data breaches rather than aiming for zero loss of personal information. He should also prepare a data breach response plan that outlines how to detect, contain, assess, report, and recover from a data breach in a timely and effective manner6 References: 4: [Data Breaches Are Inevitable: Here's How to Protect Your Business]; 5: The Top 5 Causes Of Data Breaches; 6: Data Breach Response: A Guide for Business - Federal Trade Commission
NEW QUESTION # 92
Which of the following is NOT a type of privacy program metric?
- A. Risk-reduction metrics.
- B. Value creation metrics.
- C. Data enhancement metrics.
- D. Business enablement metrics.
Answer: C
Explanation:
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 # 93
When implementing Privacy by Design (PbD), what would NOT be a key consideration?
- A. Purpose specification.
- B. Collection limitation.
- C. Data minimization.
- D. Limitations on liability.
Answer: D
Explanation:
Explanation
Limitations on liability are not a key consideration when implementing Privacy by Design (PbD). PbD is a methodology that aims to protect privacy by embedding it into the design of systems and data. The key considerations for PbD are based on seven principles that include collection limitation, data minimization, and purpose specification, among others. Limitations on liability are more relevant for contractual or legal aspects of privacy, not for design or engineering aspects. References: CIPM Study Guide, page 25; The 7 Principles of Privacy by Design.
NEW QUESTION # 94
Which of the following privacy frameworks are legally binding?
- A. Binding Corporate Rules (BCRs).
- B. Generally Accepted Privacy Principles (GAPP).
- C. Organization for Economic Co-Operation and Development (OECD) Guidelines.
- D. Asia-Pacific Economic Cooperation (APEC) Privacy Framework.
Answer: A
NEW QUESTION # 95
Under the General Data Protection Regulation (GDPR), what must be included in a written agreement between the controller and processor in relation to processing conducted on the controller's behalf?
- A. An obligation on both parties to agree to a termination of the agreement if the other party is responsible for a personal data breach.
- B. An obligation on the processor to assist the controller in complying with the controller's obligations to notify the supervisory authority about personal data breaches.
- C. An obligation on both parties to report any serious personal data breach to the supervisory authority.
- D. An obligation on the processor to report any personal data breach to the controller within 72 hours.
Answer: B
Explanation:
Explanation
Under the GDPR, a written agreement between the controller and processor must include an obligation on the processor to assist the controller in complying with the controller's obligations to notify the supervisory authority and the data subjects about personal data breaches. This is stated in Article 28(3)(f) of the GDPR1.
The other options are not required by the GDPR, although they may be included in the agreement as additional clauses. The obligation to report any personal data breach to the controller within 72 hours is imposed on the processor by Article 33(2) of the GDPR1, not by the agreement. The obligation to report any serious personal data breach to the supervisory authority is imposed on the controller by Article 33(1) of the GDPR1, not by the agreement. The termination of the agreement in case of a personal data breach is not a mandatory provision under the GDPR, but rather a contractual matter that may depend on the circumstances and severity of the breach. References: GDPR
NEW QUESTION # 96
In a sample metric template, what does "target" mean?
- A. The percentage of completion
- B. The threshold for a satisfactory rating
- C. The suggested volume of data to collect
- D. The frequency at which the data is sampled
Answer: C
NEW QUESTION # 97
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.
What should you do first to ascertain additional information about the loss of data?
- A. Interview the person reporting the incident following a standard protocol.
- B. Call the police to investigate even if you are unsure a crime occurred.
- C. Check company records of the latest backups to see what data may be recoverable.
- D. Investigate the background of the person reporting the incident.
Answer: A
Explanation:
Explanation
This answer is the best way to ascertain additional information about the loss of data, as it allows you to gather relevant facts and details from the person who witnessed or experienced the incident. A standard protocol for interviewing the person reporting the incident should include questions such as:
* When and where did the incident occur?
* What type and amount of data was involved?
* How was the data stored or protected on the laptop?
* Who else had access to or knowledge of the laptop or the data?
* What actions have been taken so far to recover or secure the laptop or the data?
* How did you discover or report the incident?
* Do you have any evidence or clues about who may have taken or accessed the laptop or the data?
* Do you have any other information that may be relevant or helpful for the investigation? Interviewing the person reporting the incident following a standard protocol can help you to establish a clear timeline and scope of the incident, identify potential sources of evidence, assess the level of risk and harm to the individuals and the organization, and determine the next steps for responding to and resolving the incident. References: IAPP CIPM Study Guide, page 87; ISO/IEC 27002:2013, section 16.1.4
NEW QUESTION # 98
Your marketing team wants to know why they need a check box for their SMS opt-in. You explain it is part of the consumer's right to?
- A. Have access.
- B. Request correction.
- C. Raise complaints.
- D. Be informed.
Answer: D
Explanation:
Explanation
The marketing team needs a check box for their SMS opt-in because it is part of the consumer's right to be informed. This right means that consumers have the right to know how their personal data is collected, used, shared, and protected by the organization. The check box allows consumers to give their consent and opt-in to receive SMS messages from the organization, and also informs them of the purpose and scope of such messages. The other rights are not relevant in this case, as they are related to other aspects of data processing, such as correction, complaints, and access. References: CIPM Body of Knowledge, Domain IV: Privacy Program Communication, Section A: Communicating to Stakeholders, Subsection 1: Consumer Rights.
NEW QUESTION # 99
If done correctly, how can a Data Protection Impact Assessment (DPIA) create a win/win scenario for organizations and individuals?
- A. By better informing about the risks associated with the processing activity and improving the organization's transparency with individuals.
- B. By quickly identifying potentially problematic data attributes and reducing the risk exposure.
- C. By enabling Data Controllers to be proactive in their analysis of processing activities and ensuring compliance with the law.
- D. By allowing Data Controllers to solicit feedback from individuals about how they feel about the potential data processing.
Answer: A
Explanation:
Explanation
A Data Protection Impact Assessment (DPIA) is a process that organizations use to evaluate the potential risks associated with a specific data processing activity, and to identify and implement measures to mitigate those risks. By conducting a DPIA, organizations can proactively identify and address potential privacy concerns before they become a problem, and ensure compliance with data protection laws and regulations.
When organizations are transparent about their data processing activities and the risks associated with them, individuals are better informed about how their personal data is being used and can make more informed decisions about whether or not to provide their personal data. This creates a win/win scenario for organizations and individuals, as organizations are able to continue processing personal data in a compliant and transparent manner, while individuals are able to trust that their personal data is being used responsibly.
Additionally, by engaging with individuals in the DPIA process and soliciting their feedback, organizations can better understand the potential impact of their data processing activities on individuals and take steps to mitigate any negative impacts.
NEW QUESTION # 100
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.
Based on the scenario, what additional change will increase the effectiveness of the privacy compliance hotline?
- A. An ethics complaint department.
- B. A system for staff education.
- C. Strict communication channels.
- D. Outsourcing the hotline.
Answer: B
NEW QUESTION # 101
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 phase in the Privacy Maturity Model (PMM) does Gadgo's privacy program best exhibit?
- A. Ad hoc.
- B. Managed.
- C. Defined.
- D. Repeatable.
Answer: A
Explanation:
Explanation
This answer is the best way to describe the phase in the Privacy Maturity Model (PMM) that Gadgo's privacy program best exhibits, as it shows that the company has no formal or consistent approach to privacy protection and that its privacy practices are largely reactive, unplanned and uncoordinated. The ad hoc phase is the lowest level of maturity in the 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 ad hoc phase indicates that the organization has little or no awareness of its privacy obligations and risks, and that its privacy activities are dependent on individual efforts or initiatives, rather than on organizational policies or processes. References: IAPP CIPM Study Guide, page 891; ISO/IEC 27002:2013, section 18.1.1
NEW QUESTION # 102
What is most critical when outsourcing data destruction service?
- A. Confirm data destruction must be done on-site.
- B. Obtain a certificate of data destruction.
- C. Conduct an annual in-person audit of the provider's facilities.
- D. Ensure that they keep an asset inventory of the original data.
Answer: D
NEW QUESTION # 103
Which is TRUE about the scope and authority of data protection oversight authorities?
- A. The Office of the Privacy Commissioner (OPC) of Canada has the right to impose financial sanctions on violators
- B. No one agency officially oversees the enforcement of privacy regulations in the United States
- C. All authority in the European Union rests with the Data Protection Commission (DPC)
- D. The Asia-Pacific Economic Cooperation (APEC) Privacy Frameworks require all member nations to designate a national data protection authority
Answer: A
Explanation:
Explanation/Reference: https://www.priv.gc.ca/en/opc-actions-and-decisions/ar_index/201617/ar_201617/
NEW QUESTION # 104
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 Data Lifecycle Management (DLM) principle should the company follow if they end up allowing departments to interpret the privacy policy differently?
- A. Adequately document reasons for inconsistencies.
- B. Create categories to reflect degrees of data importance.
- C. Arrange for official credentials for staff members.
- D. Prove the authenticity of the company's records.
Answer: A
Explanation:
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 # 105
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