DSCI DCPLA Online Practice Questions and Exam Preparation

DSCI DCPLA Online Questions & Answers

• Question 11:

  Which of the following could be considered as triggers for updating privacy policy? (Choose all that apply.)

  A. Regulatory changes
  B. Privacy breach
  C. Change in service provider for an established business process
  D. Recruitment of more employees
  A. Regulatory changes
  B. Privacy breach

• Question 12:

  Which among the following would not be characteristic of a good privacy notice?

  A. Easy to understand
  B. Clear and concise
  C. Comprehensive ?explaining all the possible scenarios and processing details making the notice lengthy
  D. Multi-lingual
  C. Comprehensive ?explaining all the possible scenarios and processing details making the notice lengthy

• Question 13:

  Which of the following is not an objective of VPI?

  A. To enable identification of processes, functions and relationships handling personal information
  B. Assess the current state of data spread and transactions of the organization to map this against its privacy objectives
  C. Enable an organization to map its data operations and categorization of PI
  D. None of the above
  D. None of the above

• Question 14:

  RCI and PCM

  Given its global operations, the company is exposed to multiple regulations (privacy related) across the globe and needs to comply mostly through contracts for client relationships and directly for business functions. The corporate legal team is responsible for managing the contracts and understanding, interpreting and translating the legal requirements. There is no formal tracking of regulations done. The knowledge about regulations mainly comes through interaction with the client team. In most of the contracts, the clients have simply referred to the applicable legislations without going any further in terms of their applicability and impact on the company. Since business expansion is the priority, the contracts have been signed by the company without fully understanding their applicability and impact. Incidentally, when the privacy initiatives were being rolled out, a major data breach occurred at one of the healthcare clients located in the US. The US state data protection legislation required the client to notify the data breach. During investigations, it emerged that the data breach happened because of some vulnerability in the system owned by the client but managed by the company and the breach actually happened 5 months back and came to notice now. The system was used to maintain medical records of the patients. This vulnerability had been earlier identified by a third party vulnerability assessment of the system and the closure of vulnerability was assigned to the company. The company had made the requisite changes and informed the client. The client, however, was of the view that the changes were actually not made by the company and they therefore violated the terms of contract which stated that ?"the company shall deploy appropriate organizational and technology measures for protection of personal information in compliance with the XX state data protection legislation." The company could not produce necessary evidences to prove that the configuration changes were actually made by it (including when these were made).

  (Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion) Introduction and Background

  XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than 500 clients across industry verticals -- BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.

  The company is witnessing phenomenal growth in the BPM services over last few years including Finance and Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects. The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).

  To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens. The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.

  Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.

  Why do you think the company failed to defend itself against client accusations? (250 to 500 words)

  A. See the answer in explanation below.
  B. PlaceHolder
  C. PlaceHolder
  D. PlaceHolder
  A. See the answer in explanation below.

  ---

  Explanation/Reference:

  The company failed to defend itself against accusations by its clients most likely due to the fact that it did not have enough expertise in privacy and data protection. The company's privacy program was designed and implemented by an internal consulting arm which had limited expertise in the domain, causing the program to be inadequate for the purpose of defending itself against accusations. Moreover, since the project was driven by CIO's office, there may have been a lack of coordination between different functions like Corporate Information Security and Legal functions which could also have contributed to the failure. It is possible that there were gaps in the organizational measures deployed by XYZ as well as gaps in technology measures. For example, it is possible that although appropriate organizational measures were put in place, the technology measures were inadequate for protecting the sensitive data of its clients. In addition, it is possible that the company did not rigorously monitor compliance with these organizational and technological measures, thereby making it vulnerable to accusations by its clients. It is also likely that XYZ was unable to fully comply with applicable privacy laws and regulations in the EU due to lack of awareness about their requirements as well as insufficient resources allocated for adapting to them. The EU GDPR requires companies to implement appropriate technical and organizational measures for the protection of personal data which could have been a challenge for XYZ given its limited expertise in this domain. Furthermore, even though it may have had some understanding of the legal requirements, there may have been difficulty in properly implementing them, which could have led to the accusations by its clients. Finally, it is possible that XYZ failed to defend itself against client accusations because of a lack of communication between its different departments and functions. The company may not have had a clear understanding of the requirements and risks associated with data protection and privacy compliance which could have caused miscommunication among various stakeholders leading to inadequate responses when it was challenged by its clients. Overall this case study demonstrates the importance of properly designing and implementing an effective privacy program in order to protect sensitive data from unauthorized access or misuse. Companies should ensure that they have adequate expertise in data protection as well as sufficient resources for adapting to changing regulatory requirements in order to avoid potential legal issues arising from client accusations. Effective communication and coordination across different departments and functions is also essential for successful data protection compliance. It is recommended that companies invest in an ongoing training program to ensure that employees understand the importance of privacy, have an awareness of the legal requirements, and are able to properly implement security measures to protect sensitive data. Organizations should also consider implementing automated tools and technologies such as encryption, access control systems, identity management solutions, etc., which can help them better defend themselves against potential client accusations.

• Question 15:

  VPI

  As a starting point, the consultants undertook a visibility exercise to understand the type of personal information (PI) being dealt with within the organization and also by third parties and the scope was to cover all the client relationships (IT services and BPM both) and functions. They met with the client relationship and business function owners to collect this data. The consultants did a mapping exercise to identify PI and associated attributes including whether company directly collects the PI, how it is accessed, transmitted, stored and what are the applicable regulatory and contractual requirements. Given the enormous scale of the exercise (enterprise wide), the consultant classified the PI as financial information, health related information, personally identifiable information, etc. and collected the rest of the attributes against this classification. When understanding the underlying technology environment, the consultants restricted themselves only to the technology environment that was under company's ownership and premises and did not continue the exercise for client side environment. This was done because relationship owners seemed reluctant to share such client specific details. Only in 2 relationships, were the relationship heads proactive to introduce the consultants to the clients and get the requisite information. The analysis of the environment in these 2 relationships revealed that even though lots of restrictions were imposed at the company side, the same restrictions were not available at the client side.

  Many business functions were also availing services from third party service providers. Though these functions were aware of the type of PI dealt by third parties, they were not aware of the technology environment at the third parties. In one odd case, personal information of a company employee was accidentally leaked by the employee of the third party through the social networking site. The consultants relied on whatever information was provided by the functions w.r.t. third parties. After finishing the data collection, the consultant used the information to create information flow maps highlighting the flow of information across systems deployed at the company premises. This work helped them have a high level view of PI dealt by the company. The data collection exercise has been conducted only once by the consultants. The visibility exercise empowered the management to have a company-wide view of PI and how it flows across the organization. This information was coupled with the security controls / practices deployed at the relationship or function level to derive the risk posture of the PI.

  (Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion)

  Introduction and Background

  XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than 500 clients across industry verticals -- BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.

  The company is witnessing phenomenal growth in the BPM services over last few years including Finance and Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects.

  The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).

  To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens. The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.

  Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.

  Was the visibility exercise adequately carried out? What gaps did you notice? (250 to 500 words)

  A. See the answer in explanation below.
  B. PlaceHolder
  C. PlaceHolder
  D. PlaceHolder
  A. See the answer in explanation below.

  ---

  Explanation/Reference:

  The consultants appointed by XYZ to design and implement the enterprise wide privacy program conducted a visibility exercise. This exercise was meant to capture the current state of Personal Information (PI) flows within the organization, identify any gaps between existing security controls/practices and intended enterprise-wide PI practices. The visibility exercise also included mapping the legal obligations of the organization in protecting PI across different jurisdictions where its operations were spread. Though this exercise seemed adequate to start with, some gaps in terms of meeting the requirements of EU GDPR were noticed during course of implementation. Firstly, though the visibility exercise covered all channels through which PI would flow in and out of an organization - like email accounts, websites and physical storage locations etc., it did not cover every element of PI such as Social Security numbers and financial data. Moreover, there was no comprehensive assessment on the technical feasibility and costs associated with implementing additional measures for protecting this information. This could have been done in order to ensure that any new systems or processes introduced met the technical requirements of GDPR. Additionally, there were certain gaps in terms of external service providers who are also responsible for ensuring compliance with GDPR while processing/storing personal data on behalf of XYZ. Though XYZ had ensured that all its existing contracts contained provisions regarding compliance with legal requirements related to privacy and confidentiality, it did not carry out any due diligence exercise to ascertain whether these third-party service providers had adequate security practices in place to comply with GDPR regulations. Lastly, the visibility exercise did not cover all the legal obligations of XYZ in terms of compliance with GDPR. For instance, it did not consider any potential liabilities arising from data breaches and the process for dealing with such eventualities. Nor was any process put in place to ensure that appropriate technical and organizational measures were taken to protect PI as required by GDPR. Thus though the visibility exercise carried out by XYZ consultants seemed adequate at first glance, there were several gaps identified in terms of meeting EU's GDPR requirements. These gaps could have been addressed through a more comprehensive assessment and must be taken care of if XYZ has to realize its full potential in Europe. As GDPR is now firmly in place across the continent, companies cannot ignore its regulations and must take necessary action to ensure compliance. This includes making sure that every element of PI is taken into consideration while designing an enterprise-wide privacy program, due diligence with regards to external service providers who process/store data on behalf of XYZ, and establishing a comprehensive legal framework for dealing with any potential liabilities arising from data breaches. In short, if XYZ does not address these gaps effectively, it may find itself in a vulnerable position in terms of protecting personal information as required by applicable laws. It will also be at risk of facing significant fines or other penalties.

• Question 16:

  Which of the following does the `Privacy Strategy and Processes' layer in the DPF help accomplish? (Choose all that apply.)

  A. Visibility over Personal Information
  B. Privacy Policy and Processes
  C. Regulatory Compliance Intelligence
  D. Information Usage and Access
  E. Personal Information Security
  A. Visibility over Personal Information
  B. Privacy Policy and Processes
  D. Information Usage and Access
  E. Personal Information Security

• Question 17:

  With respect to privacy implementation, organizations should strive for which of the following:

  A. Meaningful compliance
  B. Demonstrable accountability
  C. Checklist based exercise
  D. None of the above
  A. Meaningful compliance

• Question 18:

  What is a Data Controller?

  A. Entity that collects personal data
  B. Entity that stores personal data
  C. Entity that determines the purpose and means for data processing
  D. Entity that shares personal data with third parties
  C. Entity that determines the purpose and means for data processing

• Question 19:

  IUA and PAT

  The company has a very mature enterprise level access control policy to restrict access to information. There is a single sign-on platform available to access company resources such as email, intranet, servers, etc. However, the access policy in client relationships varies depending on the client requirements. In fact, in many cases clients provide access ids to the employees of the company and manage them. Some clients also put technical controls to limit access to information such data masking tool, encryption, and anonymizing data, among others. Some clients also record the data collection process to monitor if the employee of the company does not collect more data than is required. Taking cue from the best practices implemented by the clients, the company, through the consultants, thought of realigning its access control policy to include control on data collection and data usage by the business functions and associated third parties. As a first step, the consultants advised the company to start monitoring the PI collection, usage and access by business functions without their knowledge. The IT function was given the responsibility to do the monitoring, as majority of the information was handled electronically. The analysis showed that many times, more information than necessary was collected by the some functions, however, no instances of misuse could be identified. After few days of this exercise, a complaint was registered by a female company employee in the HR function against a male employee in IT support function. The female employee accused the male employee of accessing her photographs stored on a shared drive and posting it on a social networking site.

  (Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion)

  Introduction and Background XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than 500 clients across industry verticals -- BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.

  The company is witnessing phenomenal growth in the BPM services over last few years including Finance and Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects. The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).

  To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens. The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.

  Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.

  What should the company do to limit data collection and usage and at the same time ensure that such kinds of incidents don't reoccur? (250 to 500 words)

  A. See the answer in explanation below.
  B. PlaceHolder
  C. PlaceHolder
  D. PlaceHolder
  A. See the answer in explanation below.

  ---

  Explanation/Reference:

  XYZ should strive to create a comprehensive privacy policy that addresses all aspects of data collection, usage and storage. This will both protect the company from legal liabilities as well as create an environment of trust between customers and the organization. It should also ensure that proper security controls are in place for both on-premise systems as well as cloud services. The policy should outline details regarding access privileges and procedures for handling sensitive personal information including photographs. Further, XYZ should conduct regular training sessions with employees, especially those in IT support functions, to enhance their knowledge about the company's privacy policies and procedures. An employee code of conduct outlining restrictions on the misuse of data must be implemented and communicated clearly to all stakeholders involved in data processing activities. The company should also implement technical measures such as encryption and pseudonymisation of data, which will ensure that the data is only accessible by authorized personnel with proper privileges. In addition to this, XYZ should also create a framework for breach notification that outlines the steps to be taken in case of any unauthorized access or disclosure of information. The policy should set out procedures for assessing incidents and for informing the relevant authorities as well as affected individuals within a specified timeframe. Finally, XYZ should develop an independent monitoring mechanism to ensure compliance with its privacy policies and procedures. This may include third-party audits, regular evaluation of existing policies, and periodic reviews of employee performance. By investing in privacy and security controls at both procedural and technical levels, XYZ can ensure that it is able to keep pace with the ever-evolving privacy landscape and provide its customers with the assurance they need. This will also help the company meet any new regulatory requirements as well as ensure that similar incidents don't reoccur in the future. In this way, XYZ will be able to successfully access and tap into potential markets while reducing legal liabilities associated with data misuse. The bottom line is that proper investment in privacy and security will yield long-term dividends by enhancing customer trust in the organization. By implementing a comprehensive framework of policies, procedures and technical measures, XYZ can protect personal information from unauthorized access or disclosure, thereby providing increased assurance to customers that their data is safe and secure. In this way, the company will be better positioned to remain competitive in an increasingly competitive landscape.

• Question 20:

  Which of the following provisions of Information Technology (Amendment) Act, 2008 deal with protection of PI or SPDI of Individuals?

  A. Section 43A and Section 72A
  B. Section 43A
  C. Section 65
  D. Section 43A and Section 65
  B. Section 43A