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NEW QUESTION 1
If an organization maintains a separate ethics office, to whom would its officer typically report to in order to retain the greatest degree of independence?
- A. The Board of Directors.
- B. The Chief Financial Officer.
- C. The Human Resources Director.
- D. The organization's General Counsel.
Answer: A
NEW QUESTION 2
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?
- A. The vendor’s representative does not have enough experience
- B. Signing a contract with CRUDLOK which lasts longer than one year
- C. The company did not collect enough identifiers to monitor one’s credit
- D. You are going to notify affected individuals via a letter followed by an email
Answer: A
NEW QUESTION 3
What is the function of the privacy operational life cycle?
- A. It establishes initial plans for privacy protection and implementation
- B. It allows the organization to respond to ever-changing privacy demands
- C. It ensures that outdated privacy policies are retired on a set schedule
- D. It allows privacy policies to mature to a fixed form
Answer: A
NEW QUESTION 4
What does it mean to “rationalize” data protection requirements?
- A. Evaluate the costs and risks of applicable laws and regulations and address those that have the greatest penalties
- B. Look for overlaps in laws and regulations from which a common solution can be developed
- C. Determine where laws and regulations are redundant in order to eliminate some from requiring compliance
- D. Address the less stringent laws and regulations, and inform stakeholders why they are applicable
Answer: C
NEW QUESTION 5
SCENARIO
Please use the following to answer the next QUESTION:
Your organization, the Chicago (U.S.)-based Society for Urban Greenspace, has used the same vendor to operate all aspects of an online store for several years. As a small nonprofit, the Society cannot afford the higher-priced options, but you have been relatively satisfied with this budget vendor, Shopping Cart Saver (SCS). Yes, there have been some issues. Twice, people who purchased items from the store have had their credit card information used fraudulently subsequent to transactions on your site, but in neither case did the investigation reveal with certainty that the Society’s store had been hacked. The thefts could have been employee-related.
Just as disconcerting was an incident where the organization discovered that SCS had sold information it had collected from customers to third parties. However, as Jason Roland, your SCS account representative, points out, it took only a phone call from you to clarify expectations and the “misunderstanding” has not occurred again.
As an information-technology program manager with the Society, the role of the privacy professional is only one of many you play. In all matters, however, you must consider the financial bottom line. While these problems with privacy protection have been significant, the additional revenues of sales of items such as shirts and coffee cups from the store have been significant. The Society’s operating budget is slim, and all sources of revenue are essential.
Now a new challenge has arisen. Jason called to say that starting in two weeks, the customer data from the store would now be stored on a data cloud. “The good news,” he says, “is that we have found a low-cost provider in Finland, where the data would also be held. So, while there may be a small charge to pass through to you, it won’t be exorbitant, especially considering the advantages of a cloud.”
Lately, you have been hearing about cloud computing and you know it’s fast becoming the new paradigm for various applications. However, you have heard mixed reviews about the potential impacts on privacy protection. You begin to research and discover that a number of the leading cloud service providers have signed a letter of intent to work together on shared conventions and technologies for privacy protection. You make a note to find out if Jason’s Finnish provider is signing on.
After conducting research, you discover a primary data protection issue with cloud computing. Which of the following should be your biggest concern?
- A. An open programming model that results in easy access
- B. An unwillingness of cloud providers to provide security information
- C. A lack of vendors in the cloud computing market
- D. A reduced resilience of data structures that may lead to data loss.
Answer: B
NEW QUESTION 6
What is the name for the privacy strategy model that describes delegated decision making?
- A. De-centralized.
- B. De-functionalized.
- C. Hybrid.
- D. Matrix.
Answer: A
NEW QUESTION 7
What should a privacy professional keep in mind when selecting which metrics to collect?
- A. Metrics should be reported to the public.
- B. The number of metrics should be limited at first.
- C. Metrics should reveal strategies for increasing company earnings.
- D. A variety of metrics should be collected before determining their specific functions.
Answer: A
NEW QUESTION 8
Which of the following is NOT typically a function of a Privacy Officer?
- A. Managing an organization's information security infrastructure.
- B. Serving as an interdepartmental liaison for privacy concerns.
- C. Monitoring an organization's compliance with privacy laws.
- D. Responding to information access requests from the public.
Answer: D
NEW QUESTION 9
SCENARIO
Please use the following to answer the next QUESTION:
Edufox has hosted an annual convention of users of its famous e-learning software platform, and over time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into the others, with several thousand attendees enjoying three days of presentations, panel discussions and networking. The convention is the centerpiece of the company's product rollout schedule and a great training opportunity for current users. The sales force also encourages prospective clients to attend to get a better sense of the ways in which the system can be customized to meet diverse needs and understand that when they buy into this system, they are joining a community that feels like family.
This year's conference is only three weeks away, and you have just heard news of a new initiative supporting it: a smartphone app for attendees. The app will support late registration, highlight the featured presentations and provide a mobile version of the conference program. It also links to a restaurant reservation system with the best cuisine in the areas featured. "It's going to be great," the developer, Deidre Hoffman, tells you, "if, that is, we actually get it working!" She laughs nervously but explains that because of the tight time frame she'd been given to build the app, she outsourced the job to a local firm. "It's just three young people," she says, "but they do great work." She describes some of the other apps they have built. When asked how they were selected for this job, Deidre shrugs. "They do good work, so I chose them."
Deidre is a terrific employee with a strong track record. That's why she's been charged to deliver this rushed project. You're sure she has the best interests of the company at heart, and you don't doubt that she's under pressure to meet a deadline that cannot be pushed back. However, you have concerns about the app's handling of personal data and its security safeguards. Over lunch in the break room, you start to talk to her about it, but she quickly tries to reassure you, "I'm sure with your help we can fix any security issues if we have to, but I doubt there'll be any. These people build apps for a living, and they know what they're doing. You worry too much, but that's why you're so good at your job!"
What safeguard can most efficiently ensure that privacy protection is a dimension of relationships with vendors?
- A. Include appropriate language about privacy protection in vendor contracts.
- B. Perform a privacy audit on any vendor under consideration.
- C. Require that a person trained in privacy protection be part of all vendor selection teams.
- D. Do business only with vendors who are members of privacy trade associations.
Answer: C
NEW QUESTION 10
What is one obligation that the General Data Protection Regulation (GDPR) imposes on data processors?
- A. To honor all data access requests from data subjects.
- B. To inform data subjects about the identity and contact details of the controller.
- C. To implement appropriate technical and organizational measures that ensure an appropriate level of security.
- D. To carry out data protection impact assessments in cases where processing is likely to result in high risk to the rights and freedoms of individuals.
Answer: D
NEW QUESTION 11
Which is NOT an influence on the privacy environment external to an organization?
- A. Management team priorities.
- B. Regulations.
- C. Consumer demand.
- D. Technological advances.
Answer: C
NEW QUESTION 12
SCENARIO
Please use the following to answer the next QUESTION:
As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective. You are left contemplating:
What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success?
What are the next action steps?
Which of the following would be most effectively used as a guide to a systems approach to implementing data protection?
- A. Data Lifecycle Management Standards.
- B. United Nations Privacy Agency Standards.
- C. International Organization for Standardization 9000 Series.
- D. International Organization for Standardization 27000 Series.
Answer: D
NEW QUESTION 13
In privacy protection, what is a "covered entity"?
- A. Personal data collected by a privacy organization.
- B. An organization subject to the privacy provisions of HIPAA.
- C. A privacy office or team fully responsible for protecting personal information.
- D. Hidden gaps in privacy protection that may go unnoticed without expert analysis.
Answer: B
NEW QUESTION 14
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?
- A. Cyclical.
- B. Irregular.
- C. Statistical.
- D. Standard variance.
Answer: C
NEW QUESTION 15
“Collection”, “access” and “destruction” are aspects of what privacy management process?
- A. The data governance strategy
- B. The breach response plan
- C. The metric life cycle
- D. The business case
Answer: A
NEW QUESTION 16
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?
- A. By requiring training only on an as-needed basis.
- B. By offering alternative delivery methods for trainings.
- C. By introducing a system of periodic refresher trainings.
- D. By customizing training based on length of employee tenure.
Answer: B
NEW QUESTION 17
What are you doing if you succumb to "overgeneralization" when analyzing data from metrics?
- A. Using data that is too broad to capture specific meanings.
- B. Possessing too many types of data to perform a valid analysis.
- C. Using limited data in an attempt to support broad conclusions.
- D. Trying to use several measurements to gauge one aspect of a program.
Answer: A
NEW QUESTION 18
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