CIPM 2

This multiple choice assessment focuses on the new General Data Protection Regulation (GDPR).

The purpose of the assessment is to enable you to assess the extent and depth of your knowledge of the Data Protection Law in preparation for the CIPM.

Format: Multiple Choice

Time: 90 minutes

The result will be provided immediately, with details on all questions.

Full Name

Email

1) All of the following are factors in determining whether an organization can craft a common solution to the privacy requirements of multiple jurisdictions EXCEPT:

Effective date of most restrictive law

Implementation complexity

Legal regulations

Cost

2) An example of media sanitization would be:

Installing a password on a laptop and requiring password to be changed on a scheduled basis.

Restricting employees' thumb drive access to locked drives provided by the organization.

Performing a manufacturer's reset to restore an office printer to its factory default settings.

Implementing a blocker to limit the ability of connected devices to access specific online sites.

3) Which of the following is NOT a good reason to perform a privacy audit on a supplier?

The vendor management team is validating the supplier as part of a regular onboarding process.

The finance team has concerns that their supplier is inflating their pass-through expense costs.

The legal team received notification of a personal data breach caused by the supplier.

The IT team received a notice that the supplier is changing their cloud-storage subprocessors.

4) Please use the following information to answer the below question.

SCENARIO

Paul Daniels, with years of experience as a CEO, is worried about his son Carlton's successful venture, called ''Gadgo''.
A technological innovator in the communication industry that quickly became profitable, Gadgo has moved beyond its start-up 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 is 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 would be the best kind of audit to recommend for Gadgo?

A supplier audit

An internal audit

A third -party audit

A self-certification

5) Each of the following organizations could consider developing a highly centralized privacy team structure EXCEPT:

Grape2Table, a small to medium-sized enterprise sourcing fine wines direct from vineyards for its customers, with multiple offices throughout France.

SudsLow, a large franchise of tradespeople performing cleaning services across the United States with all executive management based in the central HQ in Ohio.

DiverzityCorp, an industrial conglomerate with multiple product and service lines with separate divisions based in the U.S., Brazil and China, each with its own management team.

Hoopdehoop, an online retail company that sells children's toys and games throughout multiple countries in the EU, through a variety of different websites, but is based in the Netherlands.

6) When conducting a baseline assessment of your privacy program, you should:

Ensure your documentation reflects the expected future state of the program.

Document areas of remediation that are currently in progress.

Quantify the costs of existing and needed technical controls.

Establish a system for implementing privacy by design.

7) Please use the following information to answer the below question.

SCENARIO

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 process could most effectively be used to add privacy protections to a new, comprehensive program being developed at Consolidated?

Privacy by Design

Privacy Step Assessment

Information Security Planning

Innovation Privacy Standards

8)Please use the following information to answer the below question.

SCENARIO

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?

Auditing

Monitoring

Assessment

Forensics

9) Please use the following information to answer the below question.

SCENARIO

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?

How can Consolidator's privacy training program best be further developed?

Through targeted curricular designed for specific departments

By adopting e-learning to reduce the need for instructors

By using industry standard off-the-shelf programs

Through a review of recent data breaches

10) Please use the following information to answer the below question.

SCENARIO

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?

Data Life Cycle Management Standards

United Nations Privacy Agency Standards

International Organization for Standardization 9000 Series

International Organization for Standardization 27000 Series

11) Where should an organization's procedures for resolving consumer complaints about privacy protection be found?

In the emergency response plan.

In memoranda from the CEO.

In written policies regarding privacy.

In the minutes of organizational board meetings.

12) An organization is establishing a mission statement for its privacy program. Which of the following statements would be the best to use?

This privacy program encourages cross-organizational collaboration which will stop all data breaches

Our organization was founded in 2054 to reduce the chance of a future disaster like the one that occurred ten years ago. All individuals from our area of the country should be concerned about a future disaster. However, with our privacy program, they should not be concerned about the misuse of their information.

The goal of the program is to protect the privacy of all individuals who support our organization. To meet this goal, we must work to comply with all applicable privacy laws.

In The next 20 years, our privacy program should be able to eliminate 80% of our current breaches. To do this, everyone in our organization must complete our annual privacy training course and all personally identifiable information must be inventoried

13) Read the following steps:

Perform frequent data back-ups.
Perform test restorations to verify integrity of backed-up data
Maintain backed-up data offline or on separate servers.

These steps can help an organization recover from what?

Phishing attacks

Authorization errors

Ransomware attacks

Stolen encryption keys

14) Which is the best way to view an organization's privacy framework?

As an industry benchmark that can apply to many organizations

As a fixed structure that directs changes in the organization

As an aspirational goal that improves the organization

As a living structure that aligns to changes in the organization

15) An organization’s business continuity plan or disaster recovery plan does NOT typically include what?

Recovery time objectives

Emergency Response Guidelines

Statement of organizational responsibilities

Retention schedule for storage and destruction of information

16) Please use the following to answer the next question:

SCENARIO

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 non-profit, 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 will not be exorbitant, especially considering the advantages of a cloud”.

Lately, you have been hearing about cloud computing and you know it is 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.

What process can best answer your questions about the vendors data security safeguards?

A second party of supplier audit reference check with other clients

A reference check with other clients

A table top demonstration of a potential threat

Public records search for earlier legal violations

17) Please use the following information to answer the below question.

SCENARIO

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 non-profit, 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 will not be exorbitant, especially considering the advantages of a cloud.'

Lately, you have been hearing about cloud computing and you know it is 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.

What is the best way for your vendor to be clear about the Society's breach notification expectations?

Include notification provisions in the vendor contract

Arrange regular telephone check-ins reviewing expectations

Send a memorandum of understanding on breach notification

Email the regulations that require breach notifications

18) Collection, access* and destruction are aspects of what privacy management process?

The data governance strategy

The breach response plan

The metric life cycle

The business case

19) What are nongovernmental organizations that advocate for privacy protection known as?

External privacy organizations.

Privacy policy review boards

Privacy trade associations.

Political action committees or PACs.

20) Please use the following to answer the next question:

SCENARIO

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 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 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 a user’s sensitive medical information for the medical appointment scheduler. In fact, all the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyse 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?

Storage of medical data in the cloud is not permissible under the General Data Protection Regulation (GDPR)

Data access is not limited to those who “need to know” for their role

Collection of data without a defined purpose might violate the fairness principle

Encryption of the data at rest prevents European users from having the right of access and the right of portability of their data portability of their data

21) Please use the following to answer the next question.

SCENARIO

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 leamed 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 used information is stored by Handy Helper for the additional purpose of creating additional products and to analyse 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?

Document the data flows for the collected data

Conduct a privacy impact assessment (PIA) o evaluate the risks involved

Implement a policy restricting data access on a “need to know basis”

Limit data transfers to the US by keeping data collected in Europe within a local centre

22) What is one reason the European Union has enacted more comprehensive privacy laws than the United States?

To ensure adequate enforcement of existing laws

To ensure there is adequate funding for enforcement

To allow separate industries to set privacy standards

To allow the free movement of data between member countries

23) The General Data Protection Regulation (GDPR) specifies fines that may be levied against data controllers for certain infringements. Which of the following will be subject to administrative fines of up to 10 000 000 EUR, or in the case of an undertaking, up to 2% of the total worldwide annual turnover of the preceding financial year?

Failure to demonstrate that consent was given by the data subject to the processing of their personal data where it is used as the basis for processing

Failure to implement technical and organizational measures to ensure data protection is enshrined by design and default

Failure to process personal information in a manner compatible with its original purpose

Failure to provide the means for a data subject to rectify inaccuracies in personal data

24) In regards to the collection of personal data conducted by an organization, what must the data subject be allowed to do?

Evaluate the qualifications of a third-party processor before any data is transferred to that processor

Obtain a guarantee of prompt notification in instances involving unauthorized access of the data

Set a time limit as to how long the personal data may be stored by the organization

Challenge the authenticity of the personal data and have it corrected if needed

25) Who is considered a primary audience for metrics data?

Information security officers.

Chief financial officers.

Stockholders.

External regulatory bodies.

26) Please use the following to answer the next question.

SCENARIO

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 leamed about the AICPA (American Institute of Certified Public Accountants)/ClCA (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.

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 harbour 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 manoeuvres 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 regarding recent security incidents, which of the following should he suggest as a priority for Treasure Box?

Appointing an internal ombudsman to address employee complaints regarding hours and pay

Using a third-party auditor to address privacy protection issues not recognized by the prior internal audits

Working with the Human Resources department to make screening procedures for potential employees more rigorous

Evaluating the company’s ability to handle personal health information if the plan to acquire the medical supply company goes forward

27) Please use the following to answer the next question.

SCENARIO

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 leamed about the AICPA (American Institute of Certified Public Accountants)/ClCA (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 lunchroom 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 harbour 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 manoeuvres 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?

Awareness campaigns with confusing information

Obsolete data processing systems

Outdated security frameworks

Potential in-house threats

28) Please use the following to answer the next question:

SCENARIO

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 Accountants) /ClCA (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 harbour 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 manoeuvres 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 interview him that he is right for the job.

In consideration of the company's new initiatives, which of the following laws and regulations would be most appropriate for Albert to mention at the interview as a priority concern for the privacy team?

Gramm-Leach-Bliley Act (GLBA)

The General Data Protection Regulation (GDPR)

The Telephone Consumer Protection Act (TCPA)

Health Insurance Portability and Accountability Act (HIPAA)

29) Please use the following to answer the next question:

SCENARIO

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 Accountants) ClCA (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 tum over 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 lunchroom 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 harbour 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 manoeuvres 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.

On which of the following topics does Albert most likely need additional knowledge?

The role of privacy in retail companies

The necessary maturity level of privacy programs

The possibility of delegating responsibilities related to privacy

The requirements for a managerial position with privacy protection duties

30) Please use the following to answer the next question.

SCENARIO

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 leamed about the AICPA (American Institute of Certified Public Accountants)/ClCA (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 lunchroom 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 harbour 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 manoeuvres 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.

The company may start to earn back the trust of its customer base by following Albert's suggestion regarding which handling procedure?

Access

Correction

Escalation

Data Integrity

31) Please use the following to answer the next question.

SCENARIO

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 leamed about the AICPA (American Institute of Certified Public Accountants)/ClCA (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 lunchroom 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 harbour 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 manoeuvres will also impress the interviewers. For example, Albert is aware of the company's intention to acquire a medical supply company in the coming weeks.

With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.

What is one important factor that Albert fails to consider regarding Treasure Box's response to their recent security incident?

Who has access to the data

What the nature of the data is

How data at the company is collected

How long data at the company is kept

32) Which is NOT an influence on the privacy environment external to an organization?

Management team priorities

Regulations

Consumer demand

Technological advances

33) What is business resiliency?

How quickly a business accomplishes a merger

How well a business responds to and adapts after a disaster.

How successful a business's auditing process is.

How well a business rewards and retains its employees.

34) What role would data loss prevention software have in a privacy program?

Prevention of all data breaches caused through human error by employees.

Protection from an external hacker trying to infiltrate an organization's networks.

Training for staff on data governance and proper data classification procedures.

Monitoring of certain types of personal data disclosures to outside entities.

35) Please use the following to answer the next question.

SCENARIO

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 heard someone in the breakroom talking about some new privacy laws, but I really don’t think it affects us. Were 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 were 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 help Penny and her CEO with their objectives. what would be the most helpful approach to address her IT concerns?

Roll out an encryption policy

Undertake a table top exercise

Ensure inventory of IT assets is maintained

Host a town hall discussion for all IT employees

36) Please use the following to answer the next question.

SCENARIO

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 heard someone in the breakroom talking about some new privacy laws, but I really do not think it affects us. Were just a small company. I mean we just sell accessories online, so what is the real risk? He has also told her that he works with several small companies that help him get projects completed in a hurry. We have 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 leamed 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 were 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?

Analyse the data inventory to map data flows

Audit all vendors’ privacy practices and safeguards

Conduct a privacy impact Assessment for the company

Review all cloud contracts to identify the location of data servers used

37) Please use the following to answer the next question.

SCENARIO

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 heard someone in the breakroom talking about some new privacy laws but I really don’t think it affects us. Were 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 leamed 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 were 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?

Audit rights

Liability for a data breach

Pricing for data security protections

The data a vendor will have access to

38) What is the key factor that lays the foundation for all other elements of a privacy program?

The applicable privacy regulations

The structure of a privacy team

A privacy mission statement

A responsible internal stakeholder

39) Before determining an organization’s privacy strategy, what should a privacy program manager define?

The program framework

The program’s scope and charter

The policy life cycle

The privacy team structure

41) What is the best way understand the location, use and importance of personal data within an organization?

By analysing the data inventory

By testing the security of data systems

By evaluating methods for collecting data

By interviewing employees tasked with data entry

42) In a sample metric template, what does ‘target' mean?

The suggested volume of data to collect

The percentage of completion

The threshold for a satisfactory rating

The frequency at which the data is sampled

43) Please use the following to answer the following question:

SCENARIO

Martin Briseno is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseno 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 Briseno 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 Briseno'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 username 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. Briseno 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 was Pacific Suites responsible for protecting the sensitive information of its offshoot, PHT?

As the parent company, it should have transferred personnel to oversee the secure handling of PHTs data

As the parent company, it should have performed an assessment of PHTs infrastructure and confirmed complete separation of the two networks

As the parent company, it should have ensured its existing data access and Storage procedures were integrated into PHTs system

As the parent company, it should have replaced PHT's electronic files with hard-copy documents stored securely on site

44) Please use the following to answer the next question.

SCENARIO

Martin Briseno is the director of human resources at the Canyon City location of the US. hotel chain Pacific Suites. In 1998, Briseno 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 Briseno 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 Briseno 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 professional 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 username and password were established, users could return to check their course status, review and reprint their and sign up and pay for new courses. Between 2002 and 2008, PHT issued more than 700,000 professional certifications.

PHTs 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. Briseno 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.

What must Pacific suite’s Primary focus be as it manages this security breach?

Minimizing the amount of harm to the affected individuals

Investigating the cause and assigning responsibility

Determining whether the affected individuals should be notified

Maintaining operations and preventing publicity

45) Please use the following answer the next question:

SCENARIO

Martin Briseno is the director of human resources at the Canyon City location of the US hotel chain Pacific Suites. In 1998, Briseno 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 Briseno 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 Briseno'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 username 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.

PHTs profits declined in 2009 and 2010, the victim of industry downsizing and increased competition from e-leaming 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. Briseno 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.

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?

Use limitation

Privacy by Design

Harm minimization

Reactive risk management

46) Each of the following steps should be taken if a company wants to revise its privacy vision EXCEPT:

Evaluating the intended objectives and acquiring knowledge on privacy approaches

Gaining executive sponsor approval

Monitoring compliance with the company’s privacy policies

Communicating the organization’s privacy stance to all stakeholders

47) Please use the following to answer the next question:

SCENARIO

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 has 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 long-time confidante — wants to hold off on Anton's idea in favour 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 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 facilities system of data security, Anton should consider following through with the plan for which of the following?

Customer communication

Employee access to electronic storage

Employee advisement regarding legal matters

Controlled access at the company headquarters

48) Please use the following information to answer the below question.

SCENARIO

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 has 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 long-time confidante — wants to hold off on Anton's idea in favour 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 leaming 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.

Which of Anton’s plans for improving the data management of the company is most unachievable?

His initiative to achieve regulatory compliance

His intention to transition to electronic storage

His objective for zero loss of personal information

His intention to send notice to customers and employees

49) Please use the following information to answer the below question.

SCENARIO

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 has 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 long-time confidante wants to hold off on Anton's idea in favour 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 the data was encrypted and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all employees and customers to be safe.

Anton must also check for compliance with all legislative, regulatory. and market requirements related to privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago, but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another trusted employee with a law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should be safe for another five years, at which time he can order another check. Documentation of this analysis will show auditors due diligence.

Anton has started down a long road toward improved management of the company, but he knows the effort is worth it. Anton wants his uncle's legacy to continue for many years to come.

What would the company's legal team most likely recommend to Anton regarding his planned communication with customers?

To send consistent communication

To shift to electronic communication

To delay communications until local authorities are informed

To consider under what circumstances communication is necessary

50) Please use the following information to answer the below question.

SCENARIO

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 has 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 long-time confidante — wants to hold off on Anton's idea in favour 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 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.

Which important principle of Data Lifecycle Management (DLM) will most likely be compromised if Anton executes his plan to limit data access to himself and Kenneth?

Practicing data minimalism

Ensuring data retrievability

Implementing clear policies

Ensuring adequacy of infrastructure

1) All of the following are factors in determining whether an organization can craft a common solution to the privacy requirements of multiple jurisdictions EXCEPT:

2) An example of media sanitization would be:

3) Which of the following is NOT a good reason to perform a privacy audit on a supplier?

4) Please use the following information to answer the below question.

SCENARIO

What would be the best kind of audit to recommend for Gadgo?

5) Each of the following organizations could consider developing a highly centralized privacy team structure EXCEPT:

6) When conducting a baseline assessment of your privacy program, you should:

7) Please use the following information to answer the below question.

SCENARIO

What process could most effectively be used to add privacy protections to a new, comprehensive program being developed at Consolidated?

8)Please use the following information to answer the below question.SCENARIO

What practice would afford the Director the most rigorous way to check on the program's compliance with laws, regulations and industry best practices?

How can Consolidator's privacy training program best be further developed?

11) Where should an organization's procedures for resolving consumer complaints about privacy protection be found?

12) An organization is establishing a mission statement for its privacy program. Which of the following statements would be the best to use?

13) Read the following steps:

These steps can help an organization recover from what?

14) Which is the best way to view an organization's privacy framework?

15) An organization’s business continuity plan or disaster recovery plan does NOT typically include what?

SCENARIO

What process can best answer your questions about the vendors data security safeguards?

What is the best way for your vendor to be clear about the Society's breach notification expectations?

18) *Collection, *access* and *destruction* are aspects of what privacy management process?

19) What are nongovernmental organizations that advocate for privacy protection known as?

20) Please use the following to answer the next question:

SCENARIO

22) What is one reason the European Union has enacted more comprehensive privacy laws than the United States?

24) In regards to the collection of personal data conducted by an organization, what must the data subject be allowed to do?

25) Who is considered a primary audience for metrics data?

26) Please use the following to answer the next question.

Based on Albert's observations regarding recent security incidents, which of the following should he suggest as a priority for Treasure Box?

27) Please use the following to answer the next question.

SCENARIO

Based on Albert's observations, executive leadership should most likely pay closer attention to what?

28) Please use the following to answer the next question:SCENARIO

In consideration of the company's new initiatives, which of the following laws and regulations would be most appropriate for Albert to mention at the interview as a priority concern for the privacy team?

29) Please use the following to answer the next question:

SCENARIO

On which of the following topics does Albert most likely need additional knowledge?

30) Please use the following to answer the next question.

SCENARIO

The company may start to earn back the trust of its customer base by following Albert's suggestion regarding which handling procedure?

31) Please use the following to answer the next question.

SCENARIO

32) Which is NOT an influence on the privacy environment external to an organization?

33) What is business resiliency?

34) What role would data loss prevention software have in a privacy program?

35) Please use the following to answer the next question.SCENARIO

To help Penny and her CEO with their objectives. what would be the most helpful approach to address her IT concerns?

36) Please use the following to answer the next question.

SCENARIO

What is the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has?

37) Please use the following to answer the next question.

What information will be LEAST crucial from a privacy perspective in Penny's review of vendor contracts?

38) What is the key factor that lays the foundation for all other elements of a privacy program?

39) Before determining an organization’s privacy strategy, what should a privacy program manager define?

41) What is the best way understand the location, use and importance of personal data within an organization?

42) In a sample metric template, what does ‘target' mean?

43) Please use the following to answer the following question:

SCENARIO

How was Pacific Suites responsible for protecting the sensitive information of its offshoot, PHT?

44) Please use the following to answer the next question.

SCENARIO

What must Pacific suite’s Primary focus be as it manages this security breach?

45) Please use the following answer the next question:

SCENARIO

46) Each of the following steps should be taken if a company wants to revise its privacy vision EXCEPT:

47) Please use the following to answer the next question:SCENARIO

To improve the facilities system of data security, Anton should consider following through with the plan for which of the following?

48) Please use the following information to answer the below question.

SCENARIO

Which of Anton’s plans for improving the data management of the company is most unachievable?

SCENARIO

What would the company's legal team most likely recommend to Anton regarding his planned communication with customers?

50) Please use the following information to answer the below question.

SCENARIO

8)Please use the following information to answer the below question.

SCENARIO

18) Collection, access* and destruction are aspects of what privacy management process?

28) Please use the following to answer the next question:

SCENARIO

35) Please use the following to answer the next question.

SCENARIO

47) Please use the following to answer the next question:

SCENARIO