IAPP IAPP Certifications CIPM Questions & Answers

• Question 131:

  SCENARIO

  Please use the following to answer the next QUESTION:

  You lead the privacy office for a company that handles information from individuals living in several countries throughout Europe and the Americas. You begin that morning's privacy review when a contracts officer sends you a message asking for a phone call. The message lacks clarity and detail, but you presume that data was lost.

  When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating

  that the vendor improperly shared information about your customers. He called the vendor and confirmed that your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database as promised in the contract. As a result, the vendor has lost control of the data.

  The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write. You put their offer on hold and begin to develop the text around the space constraints. You are content to let the vendor's logo be associated with the notification.

  The notification explains that your company recently hired a vendor to store information about their most recent experience at St. Sebastian Hospital's Clinic for Infectious Diseases. The vendor did not encrypt the information and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about their information. They simply need to go to your company's website and watch a quick advertisement, then provide their name, email address, and month and year of birth. You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation, you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their comments back and forth. The consultant who leads the incident-response team notes that it is his first day with the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the day, they vote to proceed with the notification you wrote and use the vendor's postcards.

  Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring company with a

  convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:

  1.Send an enrollment invitation to everyone the day after the contract is signed.

  2.Enroll someone with just their first name and the last-4 of their national identifier.

  3.Monitor each enrollee's credit for two years from the date of enrollment.

  4.Send a monthly email with their credit rating and offers for credit-related services at market rates.

  5.Charge your company 20% of the cost of any credit restoration.

  You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three days later you sit down and document all that went well and all that could have gone better. You put it in a file to reference the next time an

  incident occurs.

  Regarding the credit monitoring, which of the following would be the greatest concern?

  A. The vendor's representative does not have enough experience

  B. Signing a contract with CRUDLOK which lasts longer than one year

  C. The company did not collect enough identifiers to monitor one's credit

  D. You are going to notify affected individuals via a letter followed by an email

  Correct Answer: A

• Question 132:

  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.

  Correct Answer: A

  Reference: https://vvena.nl/wp-content/uploads/2018/04/ aicpa_cica_privacy_maturity_model.pdf (page 2)

• Question 133:

  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 administrative safeguards should be implemented to protect the collected data while in use by Manasa and her product management team?

  A. Document the data flows for the collected data.

  B. Conduct a Privacy Impact Assessment (PIA) to evaluate the risks involved.

  C. Implement a policy restricting data access on a "need to know" basis.

  D. Limit data transfers to the US by keeping data collected in Europe within a local data center.

  Correct Answer: A

• Question 134:

  "Collection", "access" and "destruction" are aspects of what privacy management process?

  A. The data governance strategy

  B. The breach response plan

  C. The metric life cycle

  D. The business case

  Correct Answer: A

• Question 135:

  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.

  Correct Answer: D

• Question 136:

  SCENARIO

  Please use the following to answer the next QUESTION:

  John is the new privacy officer at the prestigious international law firm ?and;M LLP. and;M LLP is very proud of its reputation in the practice areas of Trusts and Estates and Merger and 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 AandM 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 AandM 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 the most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from AandM LLP?

  A. MessageSafe must apply due diligence before trusting Cloud Inc. with the personal data received from AandM LLP.

  B. MessageSafe must flow-down its data protection contract terms with AandM LLP to Cloud Inc.

  C. MessageSafe must apply appropriate security controls on the cloud infrastructure.

  D. MessageSafe must notify AandM LLP of a data breach.

  Correct Answer: D

• Question 137:

  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. All authority in the European Union rests with the Data Protection Commission (DPC).

  C. No one agency officially oversees the enforcement of privacy regulations in the United States.

  D. The Asia-Pacific Economic Cooperation (APEC) Privacy Frameworks require all member nations to designate a national data protection authority.

  Correct Answer: A

• Question 138:

  When supporting the business and data privacy program expanding into a new jurisdiction, it is important to do all of the following EXCEPT?

  A. Identify the stakeholders.

  B. Appoint a new Privacy Officer (PO) for that jurisdiction.

  C. Perform an assessment of the laws applicable in that new jurisdiction.

  D. Consider culture and whether the privacy framework will need to account for changes in culture.

  Correct Answer: D

• Question 139:

  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.

  Which is the best way to ensure that data on personal equipment is protected?

  A. User risk training.

  B. Biometric security.

  C. Encryption of the data.

  D. Frequent data backups.

  Correct Answer: A

• Question 140:

  SCENARIO

  Please use the following to answer the next QUESTION:

  Ben works in the IT department of IgNight, Inc., a company that designs lighting solutions for its clients. Although IgNight's customer base consists primarily of offices in the US, some individuals have been so impressed by the unique

  aesthetic and energy-saving design of the light fixtures that they have requested IgNight's installations in their homes across the globe.

  One Sunday morning, while using his work laptop to purchase tickets for an upcoming music festival, Ben happens to notice some unusual user activity on company files. From a cursory review, all the data still appears to be where it is meant

  to be but he can't shake off the feeling that something is not right. He knows that it is a possibility that this could be a colleague performing unscheduled maintenance, but he recalls an email from his company's security team reminding employees to be on alert for attacks from a known group of malicious actors specifically targeting the industry. Ben is a diligent employee and wants to make sure that he protects the company but he does not want to bother his hard-working colleagues on the weekend. He is going to discuss the matter with this manager first thing in the morning but

  wants to be prepared so he can demonstrate his knowledge in this area and plead his case for a promotion. To determine the steps to follow, what would be the most appropriate internal guide for Ben to review?

  A. Incident Response Plan.

  B. Code of Business Conduct.

  C. IT Systems and Operations Handbook.

  D. Business Continuity and Disaster Recovery Plan.

  Correct Answer: B