Question # 1
| 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 the processor to report any personal data breach to the controller within 72 hours, | | B. An obligation on both parties to report any serious personal data breach to the supervisory authority | | C. An obligation on both parties to agree to a termination of the agreement if the other party is responsible for a personal data breach. | | D. 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. |
D. 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.
Explanation:
Under the GDPR, a written agreement between the controller and processor in relation to processing conducted on the controller’s behalf must include 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. This is one of the requirements under Article 28(3)(f) of the GDPR, which specifies the minimum content of such an agreement. The other options are not required by the GDPR, although they may be agreed upon by the parties as additional terms. References: GDPR, Article 28(3)(f).
Question # 2
| Which of the following actions is NOT required during a data privacy diligence process for Merger & Acquisition (M&A) deals? | | A. Revise inventory of applications that house personal data and data mapping. | | B. Update business processes to handle Data Subject Requests (DSRs). | | C. Compare the original use of personal data to post-merger use. | | D. Perform a privacy readiness assessment before the deal. |
D. Perform a privacy readiness assessment before the deal.
Explanation:
A privacy readiness assessment is not required during a data privacy diligence process for Merger & Acquisition (M&A) deals, as it is usually done before the deal to evaluate the privacy maturity and compliance level of the target organization. The other options are required during the data privacy diligence process to ensure that the personal data of both organizations are handled in accordance with the applicable laws and regulations, as well as the expectations of the data subjects and stakeholders. References: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 4: Manage data transfers.
Question # 3
| In addition to regulatory requirements and business practices, what important factors must a global privacy strategy consider? | | A. Monetary exchange. | | B. Geographic features. | | C. Political history. | | D. Cultural norms. |
D. Cultural norms.
Explanation:
In addition to regulatory requirements and business practices, an important factor that a global privacy strategy must consider is cultural norms. Different cultures may have different expectations and preferences regarding privacy, such as what constitutes personal information, how consent is obtained and expressed, how data is used and shared, and how privacy rights are enforced. A global privacy strategy should respect and accommodate these cultural differences and ensure that the organization’s privacy practices are transparent, fair, and consistent across different regions. References: [IAPP CIPM Study Guide], page 81-82; [Cultural Differences in Privacy Expectations]
Question # 4
| Which of the following information must be provided by the data controller when complying with GDPR “right to be informed” requirements? | | A. The purpose of personal data processing. | | B. The data subject’s right to withdraw consent | | C. The contact details of the Data Protection Officer (DPO). | | D. The name of any organizations with whom personal data was shared. |
C. The contact details of the Data Protection Officer (DPO).
Question # 5
| If your organization has a recurring issue with colleagues not reporting personal data breaches, all of the following are advisable to do EXCEPT? | | A. Carry out a root cause analysis on each breach to understand why the incident happened.
| | B. Communicate to everyone that breaches must be reported and how they should be reported.
| | C. Provide role-specific training to areas where breaches are happening so they are more aware.
| | D. Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.
|
D. Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.
Explanation:
Distributing a phishing exercise to all employees is not advisable to do if your organization has a recurring issue with colleagues not reporting personal data breaches. A phishing exercise is a simulated attack that tests the awareness and response of employees to malicious emails that attempt to obtain sensitive information or compromise systems. While phishing exercises can be useful to train employees on how to recognize and avoid phishing attacks, they are not directly related to the issue of reporting personal data breaches. The other options are more appropriate to address the root cause of the issue, communicate the expectations and procedures for reporting breaches, and provide specific training to areas where breaches are happening.
Question # 6
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. Investigate the background of the person reporting the incident.
| | D. Check company records of the latest backups to see what data may be recoverable.
|
A. Interview the person reporting the incident following a standard protocol.
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.
Question # 7
SCENARIO
Please use the following to answer the next QUESTION:
Your organization, the Chicago (U.S.)-based Society for Urban Greenspace, has used the same vendor to
operate all aspects of an online store for several years. As a small nonprofit, the Society cannot afford the higher-priced options, but you have been relatively satisfied with this budget vendor, Shopping Cart Saver (SCS). Yes, there have been some issues. Twice, people who purchased items from the store have had their credit card information used fraudulently subsequent to transactions on your site, but in neither case did the investigation reveal with certainty that the Society’s store had been hacked. The thefts could have been employee-related.
Just as disconcerting was an incident where the organization discovered that SCS had sold information it had collected from customers to third parties. However, as Jason Roland, your SCS account representative, points out, it took only a phone call from you to clarify expectations and the “misunderstanding” has not occurred again.
As an information-technology program manager with the Society, the role of the privacy professional is only one of many you play. In all matters, however, you must consider the financial bottom line. While these problems with privacy protection have been significant, the additional revenues of sales of items such as shirts and coffee cups from the store have been significant. The Society’s operating budget is slim, and all sources of revenue are essential.
Now a new challenge has arisen. Jason called to say that starting in two weeks, the customer data from the store would now be stored on a data cloud. “The good news,” he says, “is that we have found a low-cost provider in Finland, where the data would also be held. So, while there may be a small charge to pass through to you, it won’t be exorbitant, especially considering the advantages of a cloud.”
Lately, you have been hearing about cloud computing and you know it’s fast becoming the new paradigm for various applications. However, you have heard mixed reviews about the potential impacts on privacy protection. You begin to research and discover that a number of the leading cloud service providers have signed a letter of intent to work together on shared conventions and technologies for privacy protection. You make a note to find out if Jason’s Finnish provider is signing on.
What process can best answer your Questions about the vendor’s data security safeguards? | | A. A second-party of supplier audit
| | B. A reference check with other clients
| | C. A table top demonstration of a potential threat
| | D. A public records search for earlier legal violations
|
A. A second-party of supplier audit
Explanation:
This answer is the best process to answer Albert’s questions about the vendor’s data security safeguards, as it can provide a direct and comprehensive way to assess and verify the vendor’s compliance with the applicable laws, regulations, standards and best practices for data protection. A second-party or supplier audit is conducted by the organization that hires or contracts the vendor to evaluate their performance and alignment with the organization’s standards and expectations. A second-party or supplier audit can also help to identify any gaps, weaknesses or risks in the vendor’s data security safeguards, and to recommend or require any improvements or corrective actions.
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