Question # 1
| Which of the following best demonstrates the effectiveness of a firm’s privacy incident response process? | | A. The decrease of security breaches | | B. The decrease of notifiable breaches | | C. The increase of privacy incidents reported by users | | D. The decrease of mean time to resolve privacy incidents |
D. The decrease of mean time to resolve privacy incidents
Explanation:
The decrease of mean time to resolve privacy incidents best demonstrates the effectiveness of a firm’s privacy incident response process. This metric measures how quickly and efficiently the firm can identify, contain, analyze, remediate, and report privacy incidents. A lower mean time to resolve indicates a higher level of preparedness, responsiveness, and resilience in handling privacy incidents. References: IAPP CIPM Study Guide, page 25.
Question # 2
SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space’s practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny’s colleague in Marketing is excited by the new sales and the company’s plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her “I heard someone in the breakroom talking about some new privacy laws but I really don’t think it affects us. We’re just a small company. I mean we just sell accessories online, so what’s the real risk?” He has also told her that he works with a number of small companies that help him get projects completed in a hurry. “We’ve got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don’t have.”
In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny’s colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team “didn’t know what to do or who should do what. We hadn’t been trained on it but we’re a small team though, so it worked out OK in the end.” Penny is concerned that these issues will compromise Ace Space’s privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data “shake up”. Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space’s CEO today and has been asked to give her first impressions and an overview of her next steps.
What is the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has? | | A. Analyze the data inventory to map data flows
| | B. Audit all vendors’ privacy practices and safeguards
| | C. Conduct a Privacy Impact Assessment for the company
| | D. Review all cloud contracts to identify the location of data servers used
|
A. Analyze the data inventory to map data flows
Explanation:
The best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has is to analyze the data inventory to map data flows. A data inventory is a comprehensive record of the personal data that an organization collects, stores, uses and shares. It helps to identify the sources, categories, locations, recipients and retention periods of personal data. A data flow map is a visual representation of how personal data flows within and outside an organization. It helps to identify the data transfers, processing activities, legal bases, risks and safeguards of personal data.
By analyzing the data inventory and mapping the data flows, Penny can gain a clear picture of the personal data lifecycle at Ace Space and identify any gaps or issues that need to be addressed. For example, she can determine whether Ace Space has a lawful basis for processing personal data of EU customers, whether it has adequate security measures to protect personal data from unauthorized access or loss, whether it has appropriate contracts with its vendors and cloud providers to ensure compliance with applicable laws and regulations, and whether it has mechanisms to respect the rights and preferences of its customers.
The other options are not the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has. Auditing all vendors’ privacy practices and safeguards (B) is an important step to ensure that Ace Space’s third-party processors are complying with their contractual obligations and legal requirements, but it does not provide a comprehensive overview of Ace Space’s own personal data processing activities. Conducting a Privacy Impact Assessment (PIA) for the company © is a useful tool to assess the privacy risks and impacts of a specific project or initiative involving personal data, but it does not provide a baseline understanding of the existing personal data landscape at Ace Space. Reviewing all cloud contracts to identify the location of data servers used (D) is a relevant aspect of understanding the location of personal data, but it does not cover other aspects such as classification and processing purpose.
Question # 3
| For an organization that has just experienced a data breach, what might be the least relevant metric for a company's privacy and governance team? | | A. The number of security patches applied to company devices.
| | B. The number of privacy rights requests that have been exercised.
| | C. The number of Privacy Impact Assessments that have been completed.
| | D. The number of employees who have completed data awareness training.
|
A. The number of security patches applied to company devices.
Explanation:
The number of security patches applied to company devices might be the least relevant metric for a company’s privacy and governance team after a data breach. While security patches are important for preventing future breaches, they do not directly measure the impact or response of the current breach. The other metrics are more relevant for assessing how the company handled the breach, such as how it complied with the privacy rights of affected individuals, how it evaluated the privacy risks of its systems, and how it trained its employees on data awareness.
Question # 4
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 can Sanjay do to minimize the risks of offering the product in Europe? | | A. Sanjay should advise the distributor that Omnipresent Omnimedia has certified to the Privacy Shield Framework and there should be no issues. | | B. Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released. | | C. Sanjay should document the data life cycle of the data collected by the Handy Helper.
| | D. Sanjay should write a privacy policy to include with the Handy Helper user guide.
|
B. Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released.
Explanation:
Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released. This means that Sanjay should collaborate with Manasa and her product team to evaluate the privacy implications of the product and address any gaps or issues before launching it in Europe. This could involve conducting a PIA, applying the PbD principles, revising the consent mechanism, updating the privacy notice, ensuring compliance with data localization requirements, implementing data security measures, and limiting data access based on the least privilege principle. By doing so, Sanjay could help minimize the risks of offering the product in Europe and avoid potential violations of the General Data Protection Regulation (GDPR) or other local laws that could result in fines, lawsuits, or loss of trust.
Question # 5
| Which of the following is the optimum first step to take when creating a Privacy Officer governance model? | | A. Involve senior leadership. | | B. Provide flexibility to the General Counsel Office. | | C. Develop internal partnerships with IT and information security. | | D. Leverage communications and collaboration with public affairs teams. |
A. Involve senior leadership.
Explanation:
The optimum first step to take when creating a Privacy Officer governance model is to involve senior leadership. Senior leadership plays a crucial role in establishing and supporting a privacy program within an organization. They can provide strategic direction, allocate resources, approve policies, endorse initiatives, communicate values, and demonstrate accountability. By involving senior leadership from the beginning, a Privacy Officer can ensure that the privacy program aligns with the organization’s vision, mission, goals, and culture. Senior leadership can also help overcome potential barriers or resistance from other stakeholders by endorsing and promoting the privacy program.
References: -
CIPM Body of Knowledge (2021), Domain I: Privacy Program Governance, Section A: Privacy Governance Models, Subsection 1: Privacy Officer Governance Model
-
CIPM Study Guide (2021), Chapter 2: Privacy Governance Models, Section 2.1: Privacy Officer Governance Model
-
CIPM Textbook (2019), Chapter 2: Privacy Governance Models, Section 2.1: Privacy Officer Governance Model
-
CIPM Practice Exam (2021), Question 139
Question # 6
| 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 # 7
| Incipia Corporation just trained the last of its 300 employees on their new privacy policies and procedures.
If Incipia wanted to analyze the effectiveness of the training over the next 6 months, which form of trend analysis should they use? | | A. Cyclical. | | B. Irregular. | | C. Statistical. | | D. Standard variance. |
C. Statistical.
Explanation:
This answer is the best form of trend analysis that Incipia Corporation should use to analyze the effectiveness of the training over the next six months, as it can provide a quantitative and objective way to measure and compare the results and outcomes of the training against predefined criteria or indicators. Statistical trend analysis is a method that involves collecting, analyzing and presenting data using statistical tools and techniques, such as charts, graphs, tables or formulas.
Statistical trend analysis can help to identify patterns, changes or correlations in the data over time, as well as to evaluate the performance and impact of the training on the organization’s privacy program and objectives. References: IAPP CIPM Study Guide, page 901; ISO/IEC 27002:2013, section 18.1.3
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