Master IAPP CIPM: Your Gateway to Privacy Leadership
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.
To establish the current baseline of Ace Space's privacy maturity, Penny should consider all of the following factors EXCEPT?
Correct : D
Start a Discussions
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?
Correct : A
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.
CIPM Body of Knowledge Domain I: Privacy Program Governance - Task 1: Establish privacy program vision and strategy - Subtask 1: Identify applicable privacy laws, regulations and standards
CIPM Body of Knowledge Domain II: Privacy Program Operational Life Cycle - Task 1: Assess current state of privacy in an organization - Subtask 1: Conduct gap analysis
CIPM Study Guide - Chapter 2: Privacy Program Governance - Section 2.1: Data Inventory
CIPM Study Guide - Chapter 2: Privacy Program Governance - Section 2.2: Data Flow Mapping
Start a Discussions
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?
Correct : C
The information that will be least crucial from a privacy perspective in Penny's review of vendor contracts is the pricing for data security protections . This is because the pricing for data security protections is a business decision that does not directly affect the privacy rights and obligations of Ace Space and its customers. The pricing for data security protections may be relevant for budgeting and negotiating purposes, but it does not determine the level or adequacy of data security measures that the vendor must provide to protect personal data.
The other options are more crucial from a privacy perspective in Penny's review of vendor contracts. Audit rights (A) are important to ensure that Ace Space can monitor and verify the vendor's compliance with the contract terms and the applicable privacy laws and regulations. Audit rights allow Ace Space to access the vendor's records, systems, policies and procedures related to personal data processing and to conduct inspections or assessments as needed. Liability for a data breach (B) is important to allocate the responsibility and consequences of a data breach involving personal data that the vendor processes on behalf of Ace Space. Liability for a data breach may include indemnification, compensation, notification, remediation and termination clauses that protect Ace Space's interests and obligations in the event of a data breach. The data a vendor will have access to (D) is important to define the scope, purpose, duration and conditions of the personal data processing that the vendor will perform for Ace Space. The data a vendor will have access to may include the categories, types, sources, recipients and retention periods of personal data that the vendor will collect, store, use or share on behalf of Ace Space.
CIPM Body of Knowledge Domain II: Privacy Program Operational Life Cycle - Task 3: Implement privacy program components - Subtask 3: Establish third-party processor management program
CIPM Study Guide - Chapter 4: Privacy Program Operational Life Cycle - Section 4.3: Third-Party Processor Management
Start a Discussions
Which of the documents below assists the Privacy Manager in identifying and responding to a request from an individual about what personal information the organization holds about then with whom the information is shared?
Correct : D
A personal information inventory is a document that assists the Privacy Manager in identifying and responding to a request from an individual about what personal information the organization holds about them and with whom the information is shared. A personal information inventory is a comprehensive and detailed record of all personal information that an organization collects, uses, discloses, stores, and disposes of. It helps an organization map its data flows, assess its privacy risks, comply with its legal obligations, and respond to data subject requests. A personal information inventory should include information such as: the categories and sources of personal information; the purposes and legal bases for processing; the recipients and transfers of personal information; the retention periods and disposal methods; and the security measures and safeguards.
CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B: Protecting Personal Information, Subsection 3: Data Inventory
CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.3: Data Inventory
CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.3: Data Inventory
CIPM Practice Exam (2021), Question 138
Start a Discussions
Under the General Data Protection Regulation (GDPR), what are the obligations of a processor that engages a sub-processor?
Correct : D
Under the General Data Protection Regulation (GDPR), the obligations of a processor that engages a sub-processor are to obtain the consent of the controller and ensure the sub-processor complies with data processing obligations that are equivalent to those that apply to the processor. The GDPR defines a processor as a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller. A sub-processor is a third party that is engaged by the processor to carry out specific processing activities on behalf of the controller. The GDPR requires that the processor does not engage another processor without prior specific or general written authorization of the controller. In the case of general written authorization, the processor must inform the controller of any intended changes concerning the addition or replacement of other processors, thereby giving the controller the opportunity to object to such changes. The processor must also ensure that the same data protection obligations as set out in the contract or other legal act between the controller and the processor are imposed on that other processor by way of a contract or other legal act under Union or Member State law, .Reference:[GDPR Article 28], [CIPM - International Association of Privacy Professionals]
Start a Discussions
Total 180 questions