Certified Information Privacy Manager (CIPM) Questions and Answers
An organization is establishing a mission statement for its privacy program. Which of the following statements would be the best to use?
SCENARIO
Please use the following to answer the next question
You were recently hired by InStyte Date Corp as a privacy manager to help InStyle Data Corp become 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 paved 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 InStyte 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 you 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 team that InStyle Data Corp s privacy and information security teams are not informed of new personal data flows, new products developed by InStyte 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 have.
Through a review of InStyle Date Corp’s 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, hearth ^formation and financial information All credentialed InStyle Data Corp employees and contractors have the ability to after 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 stop 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.
Having completed the gap assessment, you and your partner need to first undertake a thorough review of?
Why were the nongovernmental privacy organizations, Electronic Frontier Foundation (EFF) and Electronic Privacy Information Center (EPIC), established?
What is the best way to understand the location, use and importance of personal data within an organization?
A minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) would include?
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?
What United States federal law requires financial institutions to declare their personal data collection practices?
SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space’s practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny’s colleague in Marketing is excited by the new sales and the company’s plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her “I heard someone in the breakroom talking about some new privacy laws but I really don’t think it affects us. We’re just a small company. I mean we just sell accessories online, so what’s the real risk?” He has also told her that he works with a number of small companies that help him get projects completed in a hurry. “We’ve got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don’t have.”
In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny’s colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team “didn’t know what to do or who should do what. We hadn’t been trained on it but we’re a small team though, so it worked out OK in the end.” Penny is concerned that these issues will compromise Ace Space’s privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data “shake up”. Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space’s CEO today and has been asked to give her first impressions and an overview of her next steps.
What is the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has?
(The individuals responsible for supporting and maintaining measurable privacy program data elements are?)
Rationalizing requirements in order to comply with the various privacy requirements required by applicable law and regulation does NOT include which of the following?
Which of the following is TRUE about a PIA (Privacy Impact Analysis)?
(Which law is applicable to the customer's right to opt out?)
Which is NOT an influence on the privacy environment external to an organization?
SCENARIO
Please use the following to answer the next QUESTION:
Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.
Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal data. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.
Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following day, to get insight into how the office computer system is currently set-up and managed.
As Richard begins to research more about Data Lifecycle Management (DLM), he discovers that the law office can lower the risk of a data breach by doing what?
Under the General Data Protection Regulation (GDPR), what must be included in a written agreement between the controller and processor in relation to processing conducted on the controller's behalf?
Which of the following is a physical control that can limit privacy risk?
Under the General Data Protection Regulation (GDPR), when would a data subject have the right to require the erasure of his or her data without undue delay?
(From a privacy perspective, what is the first concern organizations must tackle when considering using a third-party AI tool to screen job applications?)
All of the following are components of a data collection notice EXCEPT?
SCENARIO
Please use the following lo answer the next question:
You are the privacy manager within the privacy office of a National Forest Parks and Recreation Department. While having lunch with a colleague from the IT division, you learn that the IT director has put out a request for proposal (RFP) which calls for a system that collects the personal data of park attendees.
You consult with a few other colleagues in IT and learn that the RFP is worded such that it leaves it to the vendors to demonstrate what information they would collect from people who enter parks anywhere in the country, either in a vehicle or on foot. A partial list of the information collected includes:
• personal identifiers such as name, address, age, gender;
• vehicle registration information:
• facial images of park attendees;
• health information (e.g.. physical disabilities, use of mobility devices)
The stated purpose of the RFP is to:
"Improve the National Forest. Parks, and Recreation Department's ability to track and monitor service usage thereby Increasing the robustness of our customer data and to improve service offerings.''
Companies have already started submitting proposals for software solutions that address these information gathering practices. There is only one week left before the RFP closes.
The IT department has put together an RFP evaluation team but no one from the privacy office has been a Dart of the RFP ud to this point. This occurred deposite the fact….
From a privacy management perspective, what is problematic about the "stated purpose" of the RFP?
Privacy/security questionnaires are used primarily to do what?
How do privacy audits differ from privacy assessments?
Which of the following would be least beneficial in integrating privacy requirements and representation into functional areas across an organization?
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?
As a Data Protection Officer, one of your roles entails monitoring changes in laws and regulations and updating policies accordingly.
How would you most effectively execute this responsibility?
What is the key factor that lays the foundation for all other elements of a privacy program?
The theft of proprietary information could have best been prevented by?
SCENARIO
Please use the following to answer the next QUESTION:
Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green energy market. The current line of products includes wind turbines, solar energy panels, and equipment for geothermal systems. A talented team of developers means that NatGen's line of products will only continue to grow.
With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help manage the company's growth. One recent suggestion has been to combine the legal and security functions of the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in ways that will best suit their needs. She does not want administrative oversight and complex structuring to get in the way of people doing innovative work.
Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use the best possible equipment for electronic storage of customer and employee data. She simply needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before the company gets to that stage.
Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can adjust the company privacy policy according to what works best for their particular departments. NatGen's CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of normal business activities.
Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because the employees need no special preparation. They will simply have to document any concerns they hear.
Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique approach.
What Data Lifecycle Management (DLM) principle should the company follow if they end up allowing departments to interpret the privacy policy differently?
SCENARIO
Please use the following to answer the next QUESTION:
John is the new privacy officer at the prestigious international law firm – A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & 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 A&M 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 A&M 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 A&M LLP?
The first step an organization should take when considering the use of a third-party's AI-based resume ranking tool is to?
The main reason the response to this incident should be integrated into the Business Continuity Plan (BCP) is because?
When developing a privacy program and selecting a program sponsor or "champion" the least important consideration should be that they?
(Under the GDPR. international data transfer is allowed using the mechanisms in all of the following scenarios EXCEPT between companies who?)
SCENARIO
Please use the following to answer the next QUESTION:
Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.
Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal data. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.
Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the
following day, to get insight into how the office computer system is currently set-up and managed.
Richard believes that a transition from the use of fax machine to Internet faxing provides all of the following security benefits EXCEPT?
What is least likely to be achieved by implementing a Data Lifecycle Management (DLM) program?
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.
What does this example best illustrate about training requirements for privacy protection?
When building a data privacy program, what is a good starting point to understand the scope of privacy program needs?
What have experts identified as an important trend in privacy program development?
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 security controls are missing from the Eureka program?
What is the main reason to begin with 3-5 key metrics during the program development process?
What is the key privacy objective in undertaking an evaluation of technical controls?
SCENARIO
Please use the following to answer the next QUESTION:
Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.
Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.
Spencer – a former CEO and currently a senior advisor – said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling
customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.
One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason. "Breaches can happen, despite organizations' best efforts," she remarked. "Reasonable preparedness is key." She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.
Spencer replied that acting with reason means allowing security to be handled by the security functions within the company – not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.
Spencer said, "The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month."
Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.
How could the objection to Spencer's training suggestion be addressed?
SCENARIO
Please use the following to answer the next question:
Liam is the newly appointed information technology (IT) compliance manager at Mesa, a USbased outdoor clothing brand with a global E-commerce presence. During his second week, he is contacted by the company’s IT audit manager, who informs him that the auditing team will be conducting a review of Mesa’s privacy compliance risk in a month.
A bit nervous about the audit, Liam asks his boss what his predecessor had completed related to privacy compliance before leaving the company. Liam is told that a consent management tool had been added to the website and they commissioned a privacy risk evaluation from a small consulting firm last year that determined that their risk exposure was relatively low given their current control environment. After reading the consultant’s report, Liam realized that the scope of the assessment was limited to breach notification laws in the US and the Payment Card Industry’s Data Security Standard (PCI DSS).
Not wanting to let down his new team, Liam kept his concerns about the report to himself and figured he could try to put some additional controls into place before the audit. Having some privacy compliance experience in his last role, Liam thought he might start by having discussions with the E-commerce and marketing teams.
The E-commerce Director informed him that they were still using the cookie consent tool forcibly placed on the home screen by the CIO, but could not understand the point since their office was not located in California or Europe. The marketing director touted his department’s success with purchasing email lists and taking a shotgun approach to direct marketing. Both directors highlighted their tracking tools on the website to enhance customer experience while learning more about where else the customer had shopped. The more people Liam met with, the more it became apparent that privacy awareness and the general control environment at Mesa needed help.
With three weeks before the audit, Liam updated Mesa's Privacy Notice himself, which was taken and revised from a competitor’s website. He also wrote policies and procedures outlining the roles and responsibilities for privacy within Mesa and distributed the document to all departments he knew of with access to personal information.
During this time. Liam also filled the backlog of data subject requests for deletion that had been sent to him by the customer service manager. Liam worked with application owners to remove these individual's information and order history from the customer relationship management (CRM) tool, the enterprise resource planning (ERP). the data warehouse and the email server.
At the audit kick-off meeting. Liam explained to his boss and her team that there may still be some room for improvement, but he thought the risk had been mitigated to an appropriate level based on the work he had done thus far.
After the audit had been completed, the audit manager and Liam met to discuss her team’s findings, and much to his dismay. Liam was told that none of the work he had completed prior to the audit followed best practices for governance and risk mitigation. In fact, his actions only opened the company up to additional risk and scrutiny. Based on these findings. Liam worked with external counsel and an established privacy consultant to develop a remediation plan.
What key error related to program governance did Liam make prior to the audit kick-off meeting?
(What can you do from a control perspective that is most likely to mitigate the risks in how data is transferred to customers?)
What is the main purpose of a privacy program audit?
Which of the following actions is NOT required during a data privacy diligence process for Merger & Acquisition (M&A) deals?
Which of the following best describes proper compliance for an international organization using Binding Corporate Rules (BCRs) as a controller or processor?
(When a privacy program is assessing the technical and organizational risks associated with third-party vendors or processors, which internal relationship is typically the most Important early on in the process?)
Which of the following controls does the PCI DSS framework NOT require?
When a data breach incident has occurred. the first priority is to determine?
Which item below best represents how a privacy group can effectively communicate with functional areas?
What is the main function of the Asia-Pacific Economic Cooperation (APEC) Privacy Framework?
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 step in the system development process did Manasa skip?
An organization's privacy officer was just notified by the benefits manager that she accidentally sent out the retirement enrollment report of all employees to a wrong vendor.
Which of the following actions should the privacy officer take first?
(Which of the following considerations is least relevant when evaluating the privacy risks associated with the acquisition of a target company?)
What is the main reason for conducting a data inventory or data map of your organization?
Under the General Data Protection Regulation (GDPR), what are the obligations of a processor that engages a sub-processor?
You would like to better understand how your organization can demonstrate compliance with international privacy standards and identify gaps for remediation. What steps could you take to achieve this objective?
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.
To improve the facility's system of data security, Anton should consider following through with the plan for which of the following?
A Privacy Threshold Analysis (PTA), Privacy Impact Assessment (PIA) and Data Protection Impact Assessment (DPIA) are conducted during what phase of a System Development Life Cycle (SDLC)?
Incipia Corporation just trained the last of its 300 employees on their new privacy policies and procedures.
If Incipia wanted to analyze the effectiveness of the training over the next 6 months, which form of trend analysis should they use?
You are the privacy operations lead at a mid-size multi-national business to business (B2B) technology organization. The privacy program is moderately mature and you are looking to enhance and expand training and awareness at all levels of the business. You want to launch an effort that helps bring privacy into focus for specific job families, categories and lines of the business (e.g., developers, program managers, architects) but your privacy team is small and you don't have a large budget to make this happen.
You set up a meeting with internal communications to identify possible awareness opportunities to meet these objectives and have secured spots at several upcoming all team meetings to present on privacy. Your goals are to establish an enterprise-wide privacy program awareness plan and toolkit involving various stakeholders that is then tailored to internal operational departments.
(Which of the following actions would help you best determine internal stakeholders to achieve your goals using a risk-based approach?)
SCENARIO
Please use the following to answer the next question:
Recently, a boutique fashion company headquartered in California, US needed to fill a very large online order from one of their best customers located in France. The boutique did not have all the items needed to complete the order, so they asked one of their partners located in Canada to help fulfill the order. To save time, the boutique had the items shipped directly from the Canadian partner’s store to the customer’s home address. The partner sent SMS messages to provide the customer with direct shipping updates.
The merchandise arrived to the customer and they were happy with the experience. However, soon after, the customer contacted the boutique to complain that they had been receiving telemarketing calls and emails from other fashion boutiques and stores.
What should the boutique have done to properly handle and govern the customer’s personal information?
Which of the following helps build trust with customers and stakeholders?
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.
From a business standpoint, what is the most productive way to view employee use of personal equipment for work-related tasks?
While trying to e-mail her manager, an employee has e-mailed a list of all the company's customers, including their bank details, to an employee with the same name at a different company. Which of the following would be the first stage in the incident response plan under the General Data Protection Regulation (GDPR)?
An online retailer detects an incident involving customer shopping history but no keys have been compromised. The Privacy Offce is most concerned when it also involves?
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.
What is the most concerning limitation of the incident-response council?
SCENARIO
Please use the following lo answer the next question:
You are the privacy manager within the privacy office of a National Forest Parks and Recreation Department. While having lunch with a colleague from the IT division, you learn that the IT director has put out a request for proposal (RFP) which calls for a system that collects the personal data of park attendees.
You consult with a few other colleagues in IT and learn that the RFP is worded such that it leaves it to the vendors to demonstrate what information they would collect from people who enter parks anywhere in the country, either in a vehicle or on foot. A partial list of the information collected includes:
• personal identifiers such as name, address, age, gender;
• vehicle registration information:
• facial images of park attendees;
• health information (e.g.. physical disabilities, use of mobility devices)
The stated purpose of the RFP is to:
"Improve the National Forest. Parks, and Recreation Department's ability to track and monitor service usage thereby Increasing the robustness of our customer data and to improve service offerings.''
Companies have already started submitting proposals for software solutions that address these information gathering practices. There is only one week left before the RFP closes.
The IT department has put together an RFP evaluation team but no one from the privacy office has been a Dart of the RFP ud to this point. This occurred deposite the fact….
Which of the following data protection actions has been implemented by the National Forest Parks and Recreation Department?
Training and awareness metrics in a privacy program are necessary to?
All of the following would address your concern of the copy room EXCEPT?
SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space’s practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny’s colleague in Marketing is excited by the new sales and the company’s plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her “I heard someone in the breakroom talking about some new privacy laws but I really don’t think it affects us. We’re just a small company. I mean we just sell accessories online, so what’s the real risk?” He has also told her that he works with a number of small companies that help him get projects completed in a hurry. “We’ve got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don’t have.”
In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny’s colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team “didn’t know what to do or who should do what. We hadn’t been trained on it but we’re a small team though, so it worked out OK in the end.” Penny is concerned that these issues will compromise Ace Space’s privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data “shake up”. Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space’s CEO today and has been asked to give her first impressions and an overview of her next steps.
What information will be LEAST crucial from a privacy perspective in Penny’s review of vendor contracts?
SCENARIO
Please use the following lo answer the next question:
The board risk committee of your organization is particularly concerned not only by the number and frequency of data breaches reported to it over the past 12 months, but also the inconsistency in responses and poor incident response turnaround times.
Upon reviewing the current incident response plan (IRP), it was discovered that while the business continuity plan (BCP) had been updated on time, the IRP, linked to BCP. was last updated over three years ago.
The board risk committee has noted this as high risk especially since company policy is to review and update policies and plans annually. Consequently, the newly appointed data protection officer (DPO) was requested to provide a paper on how she would remediate the situation.
As a seasoned data privacy professional, you have been requested to assist the new DPO.
Which additional proactive step listed below would best mitigate these risks in the future?
SCENARIO
Please use the following to answer the next QUESTION:
Martin Briseño is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseño 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 Briseño 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 Briseño’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. Briseño 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.
In the Information Technology engineers had originally set the default for customer credit card information to “Do Not Save,” this action would have been in line with what concept?
SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space’s practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny’s colleague in Marketing is excited by the new sales and the company’s plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her “I heard someone in the breakroom talking about some new privacy laws but I really don’t think it affects us. We’re just a small company. I mean we just sell accessories online, so what’s the real risk?” He has also told her that he works with a number of small companies that help him get projects completed in a hurry. “We’ve got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don’t have.”
In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny’s colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team “didn’t know what to do or who should do what. We hadn’t been trained on it but we’re a small team though, so
it worked out OK in the end.” Penny is concerned that these issues will compromise Ace Space’s privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data “shake up”. Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space’s CEO today and has been asked to give her first impressions and an overview of her next steps.
To establish the current baseline of Ace Space’s privacy maturity, Penny should consider all of the following factors EXCEPT?
(The following are examples of privacy by design EXCEPT?)
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 can Sanjay do to minimize the risks of offering the product in Europe?
All of the following are accurate regarding the use of technical security controls EXCEPT?
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?
What practice would afford the Director the most rigorous way to check on the program's compliance with laws, regulations and industry best practices?
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?
What are you doing if you succumb to "overgeneralization" when analyzing data from metrics?
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, executive leadership should most likely pay closer attention to what?
