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NEW QUESTION 1
An organization's business continuity plan or disaster recovery plan does NOT typically include what?

  • A. Recovery time objectives.
  • B. Emergency response guidelines.
  • C. Statement of organizational responsibilities.
  • D. Retention schedule for storage and destruction of information.

Answer: D

NEW QUESTION 2
What is the name for the privacy strategy model that describes delegated decision making?

  • A. De-centralized.
  • B. De-functionalized.
  • C. Hybrid.
  • D. Matrix.

Answer: A

NEW QUESTION 3
Which of the following indicates you have developed the right privacy framework for your organization?

  • A. It includes a privacy assessment of each major system.
  • B. It improves the consistency of the privacy program.
  • C. It works at a different type of organization.
  • D. It identifies all key stakeholders by name.

Answer: A

NEW QUESTION 4
What does it mean to “rationalize” data protection requirements?

  • A. Evaluate the costs and risks of applicable laws and regulations and address those that have the greatest penalties
  • B. Look for overlaps in laws and regulations from which a common solution can be developed
  • C. Determine where laws and regulations are redundant in order to eliminate some from requiring compliance
  • D. Address the less stringent laws and regulations, and inform stakeholders why they are applicable

Answer: C

NEW QUESTION 5
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

Answer: D

NEW QUESTION 6
SCENARIO
Please use the following to answer the next QUESTION:
Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the company, Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year, news broke that a police sting operation had revealed a drug ring operating in the Providence, Rhode Island office in the United States. Video from the office's video surveillance cameras leaked to news operations showed a drug exchange between Special Handling staff and undercover officers.
In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that upper management believed had let the criminal elements conduct their illicit transactions. After a few weeks under Kelly's direction, the office became a model of efficiency and customer service. Kelly monitored his workers' activities using the same cameras that had recorded the illegal conduct of their former co-workers.
Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The company has received numerous reports of the staff leaving the office unattended. When Kelly arrived, he found that even when present, the staff often spent their days socializing or conducting personal business on their mobile phones. Again, he observed their behaviors using surveillance cameras. He issued written reprimands to six staff members based on the first day of video alone.
Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data Protection Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was told that the company's license for the cameras listed facility security as their main use, but he does not know why this matters. He has pointed out to his superiors that the company's training programs on privacy protection and data collection mention nothing about surveillance video.
You are a privacy protection consultant, hired by the company to assess this incident, report on the legal and compliance issues, and recommend next steps.
What does this example best illustrate about training requirements for privacy protection?

  • A. Training needs must be weighed against financial costs.
  • B. Training on local laws must be implemented for all personnel.
  • C. Training must be repeated frequently to respond to new legislation.
  • D. Training must include assessments to verify that the material is mastered.

Answer: B

NEW QUESTION 7
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.

Answer: B

NEW QUESTION 8
The General Data Protection Regulation (GDPR) specifies fines that may be levied against data controllers for certain infringements. Which of the following will be subject to administrative fines of up to 10 000 000 EUR, or in the case of an undertaking, up to 2% of the total worldwide annual turnover of the preceding financial year?

  • A. Failure to demonstrate that consent was given by the data subject to the processing of their personal data where it is used as the basis for processing
  • B. Failure to implement technical and organizational measures to ensure data protection is enshrined by design and default
  • C. Failure to process personal information in a manner compatible with its original purpose
  • D. Failure to provide the means for a data subject to rectify inaccuracies in personal data

Answer: A

NEW QUESTION 9
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.

Answer: C

NEW QUESTION 10
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 In
  • B. must notify A&M LLP of a data breach immediately.
  • C. MessageSafe is liable if Cloud In
  • D. fails to protect data from A&M LLP.
  • E. Cloud In
  • F. should enter into a data processor agreement with A&M LLP.
  • G. A&M LLP's service contract must be amended to list Cloud In
  • H. as a sub-processor.

Answer: A

NEW QUESTION 11
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 security controls are missing from the Eureka program?

  • A. Storage of medical data in the cloud is not permissible under the General Data Protection Regulation (GDPR)
  • B. Data access is not limited to those who “need to know” for their role
  • C. Collection of data without a defined purpose might violate the fairness principle
  • D. Encryption of the data at rest prevents European users from having the right of access and the right of portability of their data

Answer: B

NEW QUESTION 12
SCENARIO
Please use the following to answer the next QUESTION:
Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.
Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.
Spencer – a former CEO and currently a senior advisor – said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.
One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason. "Breaches can happen, despite organizations' best efforts," she remarked. "Reasonable preparedness is key." She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.
Spencer replied that acting with reason means allowing security to be handled by the security functions within the company – not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.
Spencer said, "The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month."
Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.
Based on the scenario, Nationwide Grill needs to create better employee awareness of the company's privacy program by doing what?

  • A. Varying the modes of communication.
  • B. Communicating to the staff more often.
  • C. Improving inter-departmental cooperation.
  • D. Requiring acknowledgment of company memos.

Answer: D

NEW QUESTION 13
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. Defined.
  • C. Repeatable.
  • D. Managed.

Answer: A

NEW QUESTION 14
Read the following steps:
CIPM dumps exhibit Perform frequent data back-ups.
CIPM dumps exhibit Perform test restorations to verify integrity of backed-up data.
CIPM dumps exhibit Maintain backed-up data offline or on separate servers.
These steps can help an organization recover from what?

  • A. Phishing attacks
  • B. Authorization errors
  • C. Ransomware attacks
  • D. Stolen encryption keys

Answer: C

NEW QUESTION 15
What United States federal law requires financial institutions to declare their personal data collection practices?

  • A. The Kennedy-Hatch Disclosure Act of 1997.
  • B. The Gramm-Leach-Bliley Act of 1999.
  • C. SUPCLA, or the federal Superprivacy Act of 2001.
  • D. The Financial Portability and Accountability Act of 2006.

Answer: B

NEW QUESTION 16
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