SCENARIO Please use the following to answer the next QUESTION: As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor
data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry
may note in their own program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice
president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed
the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other
employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is
fairly effective.
You are left contemplating:
What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success?
What are the next action steps?
Which of the following would be most effectively used as a guide to a systems approach to implementing data protection?
A. Data Lifecycle Management Standards.
B. United Nations Privacy Agency Standards.
C. International Organization for Standardization 9000 Series.
D. International Organization for Standardization 27000 Series.
All of the following changes will likely trigger a data inventory update EXCEPT?
A. Outsourcing the Customer Relationship Management (CRM) function.
B. Acquisition of a new subsidiary.
C. Onboarding of a new vendor.
D. Passage of a new privacy regulation.
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.
The CEO likes what he's seen of the company's improved privacy program, but wants additional assurance that it is fully compliant with industry standards and reflects emerging best practices. What would best help accomplish this goal?
A. An external audit conducted by a panel of industry experts
B. An internal audit team accountable to upper management
C. Creation of a self-certification framework based on company policies
D. Revision of the strategic plan to provide a system of technical controls
Under the General Data Protection Regulation (GDPR), which situation would be LEAST likely to require a Data Protection Impact Assessment (DPIA)?
A. A health clinic processing its patients' genetic and health data
B. The use of a camera system to monitor driving behavior on highways
C. A Human Resources department using a tool to monitor its employees' internet activity
D. An online magazine using a mailing list to send a generic daily digest to marketing emails
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.
What is one important factor that Albert fails to consider regarding Treasure Box's response to their recent security incident?
A. Who has access to the data
B. What the nature of the data is
C. How data at the company is collected
D. How long data at the company is kept
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.
What would the company's legal team most likely recommend to Anton regarding his planned communication with customers?
A. To send consistent communication.
B. To shift to electronic communication.
C. To delay communications until local authorities are informed.
D. To consider under what circumstances communication is necessary.
For an organization that has just experienced a data breach, what might be the least relevant metric for a company's privacy and governance team?
A. The number of security patches applied to company devices.
B. The number of privacy rights requests that have been exercised.
C. The number of Privacy Impact Assessments that have been completed.
D. The number of employees who have completed data awareness training.
How are individual program needs and specific organizational goals identified in privacy framework development?
A. By employing metrics to align privacy protection with objectives.
B. Through conversations with the privacy team.
C. By employing an industry-standard needs analysis.
D. Through creation of the business case.
What is the name for the privacy strategy model that describes delegated decision making?
A. De-centralized.
B. De-functionalized.
C. Hybrid.
D. Matrix.
Which of the following is TRUE about a PIA (Privacy Impact Analysis)?
A. Any project that involves the use of personal data requires a PIA
B. A Data Protection Impact Analysis (DPIA) process includes a PIA
C. The PIA must be conducted at the early stages of the project lifecycle
D. The results from a previous information audit can be leveraged in a PIA process
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