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[Hardware] CIPM Real Sheets - CIPM Certification

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【Hardware】 CIPM Real Sheets - CIPM Certification

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IAPP Certified Information Privacy Manager (CIPM) Sample Questions (Q195-Q200):NEW QUESTION # 195
Under the General Data Protection Regulation (GDPR), which of the following situations would LEAST likely require a controller to notify a data subject?
  • A. A direct marketing email is sent with recipients visible in the 'cc' field
  • B. An encrypted USB key with sensitive personal data is stolen
  • C. A hacker publishes usernames, phone numbers and purchase history online after a cyber-attack
  • D. Personal data of a group of individuals is erroneously sent to the wrong mailing list
Answer: B
Explanation:
Explanation
Under the GDPR, a controller must notify a data subject of a personal data breach without undue delay when the breach is likely to result in a high risk to the rights and freedoms of the data subject, unless one of the following conditions applies: the personal data are rendered unintelligible to any person who is not authorized to access it, such as by encryption; the controller has taken subsequent measures to ensure that the high risk is no longer likely to materialize; or the notification would involve disproportionate effort, in which case a public communication or similar measure may suffice. In this case, an encrypted USB key with sensitive personal data is stolen, but the personal data are presumably unintelligible to the thief, so the controller does not need to notify the data subject. However, the controller still needs to notify the supervisory authority within 72 hours of becoming aware of the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B:
Protecting Personal Information, Subsection 2: Data Breach Incident Planning and Management
* CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach
* Incident Planning and Management
* CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management
* CIPM Practice Exam (2021), Question 134
* GDPR Article 33 and 3412

NEW QUESTION # 196
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.
How would a strong data life cycle management policy have helped prevent the breach?
  • A. The most sensitive information would have been immediately erased and destroyed
  • B. The most important information would have been regularly assessed and tested for security
  • C. Information would have been ranked according to importance and stored in separate locations
  • D. Information would have been categorized and assigned a deadline for destruction
Answer: D

NEW QUESTION # 197
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?
  • A. An obligation on both parties to agree to a termination of the agreement if the other party is responsible for a personal data breach.
  • B. An obligation on both parties to report any serious personal data breach to the supervisory authority.
  • C. An obligation on the processor to assist the controller in complying with the controller's obligations to notify the supervisory authority about personal data breaches.
  • D. An obligation on the processor to report any personal data breach to the controller within 72 hours.
Answer: C
Explanation:
Explanation
Under the GDPR, a written agreement between the controller and processor must include an obligation on the processor to assist the controller in complying with the controller's obligations to notify the supervisory authority and the data subjects about personal data breaches. This is stated in Article 28(3)(f) of the GDPR1.
The other options are not required by the GDPR, although they may be included in the agreement as additional clauses. The obligation to report any personal data breach to the controller within 72 hours is imposed on the processor by Article 33(2) of the GDPR1, not by the agreement. The obligation to report any serious personal data breach to the supervisory authority is imposed on the controller by Article 33(1) of the GDPR1, not by the agreement. The termination of the agreement in case of a personal data breach is not a mandatory provision under the GDPR, but rather a contractual matter that may depend on the circumstances and severity of the breach. References: GDPR

NEW QUESTION # 198
A marketing team regularly exports spreadsheets to use (or analysis including customer name, birthdate and home address. These spreadsheets are routinely shared between members of various teams via email even with employees that do not need such granular data.
What is the best way to lower overall risk?
  • A. Set up security measures in the company's email client to prevent spreadsheets with customer information from accidentally being sent to external recipients.
  • B. Allow the free exchange of information to continue but require spreadsheets be password protected.
  • C. Allow only certain users to export customer data from the database.
  • D. Anonymize exportable data by creating categories of information, like age range and geographic region.
Answer: D

NEW QUESTION # 199
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?
  • A. Audit all vendors' privacy practices and safeguards
  • B. Analyze the data inventory to map data flows
  • C. Review all cloud contracts to identify the location of data servers used
  • D. Conduct a Privacy Impact Assessment for the company
Answer: B
Explanation:
The best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has is to analyze the data inventory to map data flows. A data inventory is a comprehensive record of the personal data that an organization collects, stores, uses and shares. It helps to identify the sources, categories, locations, recipients and retention periods of personal data. A data flow map is a visual representation of how personal data flows within and outside an organization. It helps to identify the data transfers, processing activities, legal bases, risks and safeguards of personal data.
By analyzing the data inventory and mapping the data flows, Penny can gain a clear picture of the personal data lifecycle at Ace Space and identify any gaps or issues that need to be addressed. For example, she can determine whether Ace Space has a lawful basis for processing personal data of EU customers, whether it has adequate security measures to protect personal data from unauthorized access or loss, whether it has appropriate contracts with its vendors and cloud providers to ensure compliance with applicable laws and regulations, and whether it has mechanisms to respect the rights and preferences of its customers.
The other options are not the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has. Auditing all vendors' privacy practices and safeguards (B) is an important step to ensure that Ace Space's third-party processors are complying with their contractual obligations and legal requirements, but it does not provide a comprehensive overview of Ace Space's own personal data processing activities. Conducting a Privacy Impact Assessment (PIA) for the company  is a useful tool to assess the privacy risks and impacts of a specific project or initiative involving personal data, but it does not provide a baseline understanding of the existing personal data landscape at Ace Space. Reviewing all cloud contracts to identify the location of data servers used (D) is a relevant aspect of understanding the location of personal data, but it does not cover other aspects such as classification and processing purpose.
Reference:
CIPM Body of Knowledge Domain I: Privacy Program Governance - Task 1: Establish privacy program vision and strategy - Subtask 1: Identify applicable privacy laws, regulations and standards CIPM Body of Knowledge Domain II: Privacy Program Operational Life Cycle - Task 1: Assess current state of privacy in an organization - Subtask 1: Conduct gap analysis CIPM Study Guide - Chapter 2: Privacy Program Governance - Section 2.1: Data Inventory CIPM Study Guide - Chapter 2: Privacy Program Governance - Section 2.2: Data Flow Mapping

NEW QUESTION # 200
......
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