IAPP IAPP Certifications CIPM Questions & Answers

• Question 171:

  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.

  Knowing that the regulator is now investigating, what would be the best step to take?

  A. Consult an attorney experienced in privacy law and litigation.

  B. Use your background and knowledge to set a course of action.

  C. If you know the organization is guilty, advise it to accept the punishment.

  D. Negotiate the terms of a settlement before formal legal action takes place.

  Correct Answer: A

• Question 172:

  SCENARIO

  Please use the following to answer the next QUESTION:

  As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data

  protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically Questionable practices, including unauthorized sales of personal data to marketers. Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that "appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.

  Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures. He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.

  What metric can Goddard use to assess whether costs associated with implementing new privacy protections are justified?

  A. Compliance ratio

  B. Cost-effective mean

  C. Return on investment

  D. Implementation measure

  Correct Answer: C

• Question 173:

  SCENARIO

  Please use the following to answer the next QUESTION:

  Martin Briseno is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseno decided to change the hotel's on-the-job mentoring model to a standardized training program for employees who were progressing from line positions into supervisory positions. He developed a curriculum comprising a series of lessons, scenarios, and assessments, which was delivered in-person to small groups. Interest in the training increased, leading Briseno to work with corporate HR specialists and software engineers to offer the program in an online format. The online program saved the cost of a trainer and allowed participants to work through the material at their own pace.

  Upon hearing about the success of Briseno's program, Pacific Suites corporate Vice President Maryanne Silva-Hayes expanded the training and offered it company-wide. Employees who completed the program received certification as a Pacific Suites Hospitality Supervisor. By 2001, the program had grown to provide industry-wide training. Personnel at hotels across the country could sign up and pay to take the course online. As the program became increasingly profitable, Pacific Suites developed an offshoot business, Pacific Hospitality Training (PHT). The sole focus of PHT was developing and marketing a variety of online courses and course progressions providing a number of professional certifications in the hospitality industry.

  By setting up a user account with PHT, course participants could access an information library, sign up for courses, and take end-of-course certification tests. When a user opened a new account, all information was saved by default, including the user's name, date of birth, contact information, credit card information, employer, and job title. The registration page offered an opt-out choice that users could click to not have their credit card numbers saved. Once a user name and password were established, users could return to check their course status, review and reprint their certifications, and sign up and pay for new courses. Between 2002 and 2008, PHT issued more than 700,000 professional certifications.

  PHT's profits declined in 2009 and 2010, the victim of industry downsizing and increased competition from e- learning providers. By 2011, Pacific Suites was out of the online certification business and PHT was dissolved. The training program's systems and records remained in Pacific Suites' digital archives, un-accessed and unused. Briseno and Silva- Hayes moved on to work for other companies, and there was no plan for handling the archived data after the program ended. After PHT was dissolved, Pacific Suites executives turned their attention to crucial day-to-day operations. They planned to deal with the PHT materials once resources allowed.

  In 2012, the Pacific Suites computer network was hacked. Malware installed on the online reservation system exposed the credit card information of hundreds of hotel guests. While targeting the financial data on the reservation site, hackers also discovered the archived training course data and registration accounts of Pacific Hospitality Training's customers. The result of the hack was the exfiltration of the credit card numbers of recent hotel guests and the exfiltration of the PHT database with all its contents.

  A Pacific Suites systems analyst discovered the information security breach in a routine scan of activity reports. Pacific Suites quickly notified credit card companies and recent hotel guests of the breach, attempting to prevent serious harm. Technical security engineers faced a challenge in dealing with the PHT data.

  PHT course administrators and the IT engineers did not have a system for tracking, cataloguing, and storing information. Pacific Suites has procedures in place for data access and storage, but those procedures were not implemented when PHT was formed. When the PHT database was acquired by Pacific Suites, it had no owner or oversight. By the time technical security engineers determined what private information was compromised, at least 8,000 credit card holders were potential victims of fraudulent activity. What must Pacific Suite's primary focus be as it manages this security breach?

  A. Minimizing the amount of harm to the affected individuals

  B. Investigating the cause and assigning responsibility

  C. Determining whether the affected individuals should be notified

  D. Maintaining operations and preventing publicity

  Correct Answer: A

• Question 174:

  SCENARIO

  Please use the following to answer the next QUESTION:

  Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has found some degree of disorganization after touring the company headquarters. His uncle Henry had always focused on

  production ?not data processing ?and Anton is concerned. In several storage rooms, he has found paper files, disks, and old computers that appear to contain the personal data of current and former employees and customers. Anton knows

  that a single break-in could irrevocably damage the company's relationship with its loyal customers. He intends to set a goal of guaranteed zero loss of personal information.

  To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the company. However, Kenneth ?his uncle's vice president and longtime confidante ?wants to hold off on Anton's idea in favor of

  converting any paper records held at the company to electronic storage. Kenneth

  believes this process would only take one or two years. Anton likes this idea; he envisions a password- protected system that only he and Kenneth can access.

  Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware store down the street

  will be responsible for their own information management. Then, any unneeded subsidiary data still in Anton's possession can be destroyed within the next few years.

  After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers. Kenneth insists that two lost hard drives in Question are not cause for concern; all of the data was encrypted and not sensitive in

  nature. Anton does not want to take any chances, however. He intends on sending notice letters to all employees and customers to be safe.

  Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago, but Anton is not confident

  about his understanding of recent online marketing laws. Anton is assigning another trusted employee with a law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should be safe for

  another five years, at which time he can order another check.

  Documentation of this analysis will show auditors due diligence.

  Anton has started down a long road toward improved management of the company, but he knows the effort is worth it. Anton wants his uncle's legacy to continue for many years to come.

  In terms of compliance with regulatory and legislative changes, Anton has a misconception regarding?

  A. The timeline for monitoring.

  B. The method of recordkeeping.

  C. The use of internal employees.

  D. The type of required qualifications.

  Correct Answer: B

• Question 175:

  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 NOT an obligation of MessageSafe as the email continuity service provider for AandM LLP?

  A. Privacy compliance.

  B. Security commitment.

  C. Certifications to relevant frameworks.

  D. Data breach notification to AandM LLP.

  Correct Answer: C

• Question 176:

  What is a key feature of the privacy metric template adapted from the National Institute of Standards and Technology (NIST)?

  A. It provides suggestions about how to collect and measure data.

  B. It can be tailored to an organization's particular needs.

  C. It is updated annually to reflect changes in government policy.

  D. It is focused on organizations that do business internationally.

  Correct Answer: A

• Question 177:

  Which of the following best supports implementing controls to bring privacy policies into effect?

  A. The internal audit department establishing the audit controls which test for policy effectiveness.

  B. The legal department or outside counsel conducting a thorough review of the privacy program and policies.

  C. The Chief Information Officer as part of the Senior Management Team creating enterprise privacy policies to ensure controls are available.

  D. The information technology (IT) group supporting and enhancing the privacy program and privacy policy by developing processes and controls.

  Correct Answer: A

• Question 178:

  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

  Correct Answer: D

• Question 179:

  SCENARIO

  Please use the following to answer the next QUESTION:

  For 15 years, Albert has worked at Treasure Box ?a mail order company in the United States (U.S.) that used to sell decorative candles around the world, but has recently decided to limit its shipments to customers in the 48 contiguous states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not being promoted, coupled with his recent interest in issues of privacy protection, have motivated Albert to be an agent of positive change. He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives aware of lapses in the company's privacy program. He feels certain he will be rewarded with a promotion for preventing negative consequences resulting from the company's outdated policies and procedures.

  For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful way to measure Treasure Box's ability to protect personal data. Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company with meeting this level in order to provide customers with the most rigorous security available.

  Albert does want to show a positive outlook during his interview. He intends to praise the company's commitment to the security of customer and employee personal data against external threats. However, Albert worries about the high turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours and low pay, as well as what seems to be flagrant disregard for company procedures.

  In addition, Treasure Box has had two recent security incidents. The company has responded to the incidents with internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help the company recover. He knows there is at least one incident the public in unaware of, although Albert does not know the details. He believes the company's insistence on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient procedure for responding to customer concerns by postal mail.

  In addition to his suggestions for improvement, Albert believes that his knowledge of the company's recent business maneuvers will also impress the interviewers. For example, Albert is aware of the company's intention to acquire a medical supply company in the coming weeks.

  With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.

  Based on Albert's observations regarding recent security incidents, which of the following should he suggest as a priority for Treasure Box?

  A. Appointing an internal ombudsman to address employee complaints regarding hours and pay.

  B. Using a third-party auditor to address privacy protection issues not recognized by the prior internal audits.

  C. Working with the Human Resources department to make screening procedures for potential employees more rigorous.

  D. Evaluating the company's ability to handle personal health information if the plan to acquire the medical supply company goes forward

  Correct Answer: D

• Question 180:

  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.

  Correct Answer: B