Question 1

A Data Privacy Officer (DPO) who posts privacy message reminders on posters and on company video screens throughout the office to reinforce the organization's privacy message is furthering which organizational program?

Options :

A : Public Service.

B : Awareness

C : Training

D : Ethics

Answer: B

Question 2

Please use the following to answer the next question:

As they company’s new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically questionable practices, including unauthorized sales of personal data to marketers. Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company’s claims that “appropriate” data protection safeguards were in place. The scandal affected the company’s business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard’s mentor, was forced to step down.

Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company’s board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures. He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. “We want Medialite to have absolutely the highest standards,” he says. “In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company’s finances. So, while I want the best solutions across the board, they also need to be cost effective.”

You are told to report back in a week’s time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.

You give a presentation to your CEO about privacy program maturity. What does it mean to have a “managed” privacy program, according to the AICPA/CICA Privacy Maturity Model?

Options :

A :

Procedures or processes exist, however they are not fully documented and do not cover all relevant aspects.

B : Procedures and processes are fully documented and implemented, and cover all relevant aspects.

C : Reviews are conducted to assess the effectiveness of the controls in place

D :

Regular review and feedback are used to ensure continuous improvement toward optimization of the given process.

Answer: B,C

Question 3

Which of the following controls does the PCI DSS framework NOT require?

Options :

A : Implement strong asset control protocols

B : Implement strong access control measures

C : Maintain an information security policy

D : Maintain a vulnerability management program

Answer: A

Question 4

SCENARIO

Please use the following to answer the next question:

Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has

found some degree of disorganization after touring the company headquarters. His uncle Henry had always

focused on production – not data processing – and Anton is concerned. In several storage rooms, he has found

paper files, disks, and old computers that appear to contain the personal data of current and former employees

and customers. Anton knows that a single break-in could irrevocably damage the company's relationship with

its loyal customers. He intends to set a goal of guaranteed zero loss of personal information.

To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the

company. However, Kenneth – his uncle's vice president and longtime confidante – wants to hold off on Anton's

idea in favor of converting any paper records held at the company to electronic storage. Kenneth believes this

process would only take one or two years. Anton likes this idea; he envisions a password-protected system that

only he and Kenneth can access.

Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it

will simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware

store down the street will be responsible for their own information management. Then, any unneeded subsidiary

data still in Anton's possession can be destroyed within the next few years.

After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers.

Kenneth insists that two lost hard drives in question are not cause for concern; all of the data was encrypted

and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice

letters to all employees and customers to be safe.

Anton must also check for compliance with all legislative, regulatory, and market requirements related to

privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago,

but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another

trusted employee with a law background the task of the compliance assessment. After a thorough analysis,

Anton knows the company should be safe for another five years, at which time he can order another check.

Documentation of this analysis will show auditors due diligence.

Anton has started down a long road toward improved management of the company, but he knows the effort is

worth it. Anton wants his uncle's legacy to continue for many years to come.

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?

Options :

A : Practicing data minimalism.

B : Ensuring data retrievability

C : Implementing clear policies

D : Ensuring adequacy of infrastructure

Answer: B

Question 5

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

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