When vetting third-party processors of data protected by the General Data Protection Regulation (GDPR), why is it important to know the physical location of stored personal data from clients?
A. To determine their incidence response time.
B. To determine the country laws that would govern the contract.
C. To determine the likelihood of a security breach in the location.
D. To ensure the country has adequate protection or if safeguards are required.
SCENARIO
Please use the following to answer the next question:
You were recently hired by InStyle Data Corp. as a privacy manager to help InStyle Data Corp. became compliant with a new data protection law.
The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue
companies that don't comply with the new law.
You are paired with a security manager and tasked with reviewing InStyle Data Corp.'s current state and advising the business how it can meet the “reasonable and appropriate security’ requirement. InStyle Data Corp has grown rapidly and
has not kept a data inventory or completed a data mapping. InStyle Data Corp. has also developed security-related policies ad hoc and many have never been implemented. The various teams involved in the creation and testing of InStyle
Data Corp.'s products experience significant turnover and do not have well defined roles. There's little documentation addressing what personal data is processed by which product and for what purpose.
Work needs to begin on this project immediately so that InStyle Data Corp. can become compliant by the time the law goes into effect. You and your partner discover that InStyle Data Corp. regularly sends files containing sensitive personal
data back to its customers, through email, sometimes using InStyle Data Corp employees personal email accounts. You also learn that InStyle Data Corp.'s privacy and information security teams are not informed of new personal data flows,
new products developed by InStyle Data Corp. that process personal data, or updates to existing InStyle Data Corp. products that may change what or how the personal data is processed until after the product or update has gone live.
Through a review of InStyle Data Corp’ test and development environment logs, you discover InStyle Data Corp. sometimes gives login credentials to any InStyle Data Corp. employee or contractor who requests them. The test environment
only contains dummy data, but the development environment contains personal data, including Social Security Numbers, health information, and financial information. All credentialed InStyle Data Corp. employees and contractors have the
ability to alter and delete personal data in both environments regardless of their role or what project they are working on.
You and your partner provide a gap assessment citing the issues you spotted, along with recommended remedial actions and a method to measure implementation. InStyle Data Corp. implements all of the recommended security controls.
You review the processes, roles, controls, and measures taken to appropriately protect the personal data at every step. However, you realize there is no plan for monitoring and nothing in place addressing sanctions for violations of the
updated policies and procedures. InStyle Data Corp. pushes back, stating they do not have the resources for such monitoring.
In order to mitigate the risk of new data flows, products, or updates that cause InStyle Data Corp. to be noncompliant with the new law you should establish?
A. A process whereby privacy and security would be consulted right before the do-live date for the new data flows, products, or updates.
B. Best practices that require employees to sign an attestation that they understand the sensitivity of new data flows, products, or updates.
C. Access controls based on need-to-know basis for InStyle Data Corp. employees so that not everyone has access to personal data in data flows, products, or updates.
D. Requirements for a Privacy Impact Assessment (PIA) / Data Privacy Impact Assessment (DPIA) as part of the business’ standard process in developing new data flows, products, or updates.
SCENARIO
Please use the following to answer the next question:
You were recently hired by InStyle Data Corp. as a privacy manager to help InStyle Data Corp. became compliant with a new data protection law.
The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue
companies that don't comply with the new law.
You are paired with a security manager and tasked with reviewing InStyle Data Corp.'s current state and advising the business how it can meet the “reasonable and appropriate security’ requirement. InStyle Data Corp has grown rapidly and
has not kept a data inventory or completed a data mapping. InStyle Data Corp. has also developed security-related policies ad hoc and many have never been implemented. The various teams involved in the creation and testing of InStyle
Data Corp.'s products experience significant turnover and do not have well defined roles. There's little documentation addressing what personal data is processed by which product and for what purpose.
Work needs to begin on this project immediately so that InStyle Data Corp. can become compliant by the time the law goes into effect. You and your partner discover that InStyle Data Corp. regularly sends files containing sensitive personal
data back to its customers, through email, sometimes using InStyle Data Corp employees personal email accounts. You also learn that InStyle Data Corp.'s privacy and information security teams are not informed of new personal data flows,
new products developed by InStyle Data Corp. that process personal data, or updates to existing InStyle Data Corp. products that may change what or how the personal data is processed until after the product or update has gone live.
Through a review of InStyle Data Corp’ test and development environment logs, you discover InStyle Data Corp. sometimes gives login credentials to any InStyle Data Corp. employee or contractor who requests them. The test environment
only contains dummy data, but the development environment contains personal data, including Social Security Numbers, health information, and financial information. All credentialed InStyle Data Corp. employees and contractors have the
ability to alter and delete personal data in both environments regardless of their role or what project they are working on.
You and your partner provide a gap assessment citing the issues you spotted, along with recommended remedial actions and a method to measure implementation. InStyle Data Corp. implements all of the recommended security controls.
You review the processes, roles, controls, and measures taken to appropriately protect the personal data at every step. However, you realize there is no plan for monitoring and nothing in place addressing sanctions for violations of the
updated policies and procedures. InStyle Data Corp. pushes back, stating they do not have the resources for such monitoring.
What aspect of the data management life cycle have you as Privacy Manager NOT accounted for?
A. Auditability.
B. Minimalism.
C. Enforcement.
D. Retrievability.
Under the European Data Protection Board (formerly Article 29 Working Party), which Processing operation would require a Data Protection Impact Assessment (DPIA)?
A. An online newspaper using its subscriber list to email a daily newsletter.
B. A healthcare clinic that processes personal data of its patients in its billing system.
C. A hospital processing patient's generic and health data in its hospital information system.
D. An online store displaying advertisements based on items viewed or purchased on its own website.
What is the Privacy Officer's first action after being told that her firm is planning to sell its credit card processing business?
A. Perform a Record of Processing Activity (ROPA).
B. Review technical security controls.
C. Review contractual obligations.
D. Review data mapping.
SCENARIO
Please use the following to answer the next question:
You were recently hired by InStyle Data Corp. as a privacy manager to help InStyle Data Corp. became compliant with a new data protection law.
The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue
companies that don't comply with the new law.
You are paired with a security manager and tasked with reviewing InStyle Data Corp.'s current state and advising the business how it can meet the “reasonable and appropriate security” requirement. InStyle Data Corp has grown rapidly and
has not kept a data inventory or completed a data mapping. InStyle Data Corp. has also developed security-related policies ad hoc and many have never been implemented. The various teams involved in the creation and testing of InStyle
Data Corp.'s products experience significant turnover and do not have well defined roles. There's little documentation addressing what personal data is processed by which product and for what purpose.
Work needs to begin on this project immediately so that InStyle Data Corp. can become compliant by the time the law goes into effect. You and your partner discover that InStyle Data Corp. regularly sends files containing sensitive personal
data back to its customers, through email, sometimes using InStyle Data Corp employees personal email accounts. You also learn that InStyle Data Corp.'s privacy and information security teams are not informed of new personal data flows,
new products developed by InStyle Data Corp. that process personal data, or updates to existing InStyle Data Corp. products that may change what or how the personal data is processed until after the product or update has gone live.
Through a review of InStyle Data Corp’ test and development environment logs, you discover InStyle Data Corp. sometimes gives login credentials to any InStyle Data Corp. employee or contractor who requests them. The test environment
only contains dummy data, but the development environment contains personal data, including Social Security Numbers, health information, and financial information. All credentialed InStyle Data Corp. employees and contractors have the
ability to alter and delete personal data in both environments regardless of their role or what project they are working on.
You and your partner provide a gap assessment citing the issues you spotted, along with recommended remedial actions and a method to measure implementation. InStyle Data Corp. implements all of the recommended security controls.
You review the processes, roles, controls, and measures taken to appropriately protect the personal data at every step. However, you realize there is no plan for monitoring and nothing in place addressing sanctions for violations of the
updated policies and procedures. InStyle Data Corp. pushes back, stating they do not have the resources for such monitoring.
Based on your findings regarding how data is transferred to InStyle Data Corp.'s customers, what can you do from a control perspective that is most likely to mitigate risk from this data processing activity?
A. Require in the customer contract that the customer only allow an authorized end user to open the file.
B. Keep an adult log of files with sensitive personal data sent to the customer and the intended recipient.
C. Allow InStyle Data Corp. employees to only use their personal email address to send files if it's an emergency.
D. Implement a method of data transfer for the files containing sensitive personal information with end-to-end encryption.
All of the following are components of a data collection notice EXCEPT identification of?
A. Data subject rights.
B. How the data is processed securely.
C. Potential uses of personal information in the future.
D. The metadata which could be generated from collection of the information.
Under the General Data Protection Regulation (GDPR), what obligation does a data controller or processor have after appointing a Data Protection Officer (DPO)?
A. To submit for approval to the DPO a code of conduct to govern organizational practices and demonstrate compliance with data protection principles.
B. To provide resources necessary to carry out the defined tasks of the DPO and to maintain their expert knowledge.
C. To ensure that the DPO acts as the sole point of contact for individuals’ questions about their personal data.
D. To ensure that the DPO receives sufficient instructions regarding the exercise of their defined tasks.
What is the name for the privacy strategy model that describes delegated decision making?
A. Decentralized.
B. Hierarchical.
C. Localized.
D. Hybrid.
Which aspect of a privacy program can best aid an organization's response time to a Data Subject Access Request (DSAR)?
A. Conducting privacy training.
B. Maintaining a written DSAR policy.
C. Creating a comprehensive data inventory.
D. Implementing Privacy Impact Assessment (PIAs).
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