Question 1

You would like your organization to be independently audited to demonstrate compliance with international

privacy standards and to identify gaps for remediation.

Which type of audit would help you achieve this objective?

Options :

A : First-party audit.

B : Second-party audit.

C : Third-party audit.

D : Fourth-party audit.

Answer: C

Question 2

SCENARIO

Please use the following to answer the next question:

As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your

accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of

relatively minor data breaches that could easily have been worse. However, you have not had a reportable

incident for the three years that you have been with the company. In fact, you consider your program a model

that others in the data storage industry may note in their own program development.

You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward

coherence across departments and throughout operations. You were aided along the way by the program's

sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding

of the need for change.

Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both

the executive team and frontline personnel working with data and interfacing with clients. Through the use of

metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that

easily could occur given the current state of operations, you soon had the leaders and key decision-makers

largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each

department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin

putting the proper procedures into place.

Now, privacy protection is an accepted component of all current operations involving personal or protected data

and must be part of the end product of any process of technological development. While your approach is not

systematic, it is fairly effective.

You are left contemplating:

What must be done to maintain the program and develop it beyond just a data breach prevention program?

How can you build on your success?

What are the next action steps?

What stage of the privacy operational life cycle best describes the company's current privacy program?

Options :

A : Assess

B : Protect

C : Respond

D : Sustain

Answer: D

Question 3

How do privacy audits differ from privacy assessments?

Options :

A : They are non-binding.

B : They are evidence-based.

C : They are based on standards.

D : They are conducted by external parties.

Answer: B

Question 4

SCENARIO

Please use the following to answer the next question:

Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the

development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can

be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After

having had a successful launch in the United States, the Handy Helper is about to be made available for

purchase worldwide.

The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the

whole family, including children, but does not provide any further detail or privacy notice. In order to use the

application, a family creates a single account, and the primary user has access to all information about the

other users. Upon start up, the primary user must check a box consenting to receive marketing emails from

Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.

Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European

distributor of Handy Helper when he fielded many questions about the product from the distributor. Sanjay

needed to look more closely at the product in order to be able to answer the questions as he was not involved

in the product development process.

In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's

sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is

stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the

product. This data is all stored in the cloud and is encrypted both during transmission and at rest.

Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent

Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is

hoping that at some point in the future, the data will reveal insights that could be used to create a fully

automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is

considered a long-term goal.

What administrative safeguards should be implemented to protect the collected data while in use by Manasa

and her product management team?

Options :

A : Document the data flows for the collected data

B : Conduct a Privacy Impact Assessment (PIA) to evaluate the risks involved.

C : Implement a policy restricting data access on a "need to know" basis.

D : Limit data transfers to the US by keeping data collected in Europe within a local data center.

Answer: C

Question 5

SCENARIO

Please use the following to answer the next question:

Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last

week, a data processing firm used by the company reported that its system may have been hacked, and

customer data such as names, addresses, and birthdays may have been compromised. Although the attempt

was proven unsuccessful, the scare has prompted several Nationwide Grill executives to question the

company's privacy program at today's meeting.

Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging

Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if

there had been an actual breach, the chances of a successful suit against the company were slim. But Alice

remained unconvinced.

Spencer – a former CEO and currently a senior advisor – said that he had always warned against the use of

contractors for data processing. At the very least, he argued, they should be held contractually liable for telling

customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company

name for a problem it did not cause.

One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason.

"Breaches can happen, despite organizations' best efforts," she remarked. "Reasonable preparedness is key."

She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its

financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD

executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of

cultivating relationships, Haley was able to successfully manage the company's incident response.

Spencer replied that acting with reason means allowing security to be handled by the security functions within

the company – not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training

employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters,

emails, and memos from both HR and the ethics department related to the company's privacy program. Both

the volume and the duplication of information means that it is often ignored altogether.

Spencer said, "The company needs to dedicate itself to its privacy program and set regular in-person trainings

for all staff once a month."

Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR

departments need to have flexibility with their training schedules. Silently, Natalia agreed.

Based on the scenario, Nationwide Grill needs to create better employee awareness of the company's privacy

program by doing what?

Options :

A : Varying the modes of communication

B : Communicating to the staff more often

C : Improving inter-departmental cooperation

D : Requiring acknowledgment of company memos

Answer: A

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