TRUSTWORTHY IAPP CIPM PRACTICE & CIPM RELIABLE BRAINDUMPS SHEET

Trustworthy IAPP CIPM Practice & CIPM Reliable Braindumps Sheet

Trustworthy IAPP CIPM Practice & CIPM Reliable Braindumps Sheet

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IAPP Certified Information Privacy Manager (CIPM) Sample Questions (Q141-Q146):

NEW QUESTION # 141
SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space's practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny's colleague in Marketing is excited by the new sales and the company's plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her "I heard someone in the breakroom talking about some new privacy laws but I really don't think it affects us. We're just a small company. I mean we just sell accessories online, so what's the real risk?" He has also told her that he works with a number of small companies that help him get projects completed in a hurry. "We've got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don't have." In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny's colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team
"didn't know what to do or who should do what. We hadn't been trained on it but we're a small team though, so it worked out OK in the end." Penny is concerned that these issues will compromise Ace Space's privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data "shake up". Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space's CEO today and has been asked to give her first impressions and an overview of her next steps.
To establish the current baseline of Ace Space's privacy maturity, Penny should consider all of the following factors EXCEPT?

  • A. Ace Space's documented procedures
  • B. Ace Space's employee training program
  • C. Ace Space's content sharing practices on social media
  • D. Ace Space's vendor engagement protocols

Answer: C

Explanation:
The factor that Penny should not consider to establish the current baseline of Ace Space's privacy maturity is Ace Space's content sharing practices on social media. This is because this factor is not directly related to the privacy program elements that Penny should assess, such as leadership and organization, privacy risk management, engineering and information security, incident response, individual participation, transparency and redress, privacy training and awareness, and accountability1. The other factors are relevant to these elements and can help Penny measure the current state of Ace Space's privacy program against a recognized maturity model, such as the Privacy Capability Maturity Model (PCMM) developed by the Association of Corporate Counsel2. For example:
* Ace Space's documented procedures can help Penny evaluate the level of formalization and standardization of the privacy policies and practices across the organization, as well as the alignment with the applicable legal and regulatory requirements1, 2.
* Ace Space's employee training program can help Penny assess the level of awareness and competence of the staff on privacy issues and responsibilities, as well as the effectiveness and frequency of the training delivery and evaluation1, 2.
* Ace Space's vendor engagement protocols can help Penny determine the level of due diligence and oversight of the third parties that process personal data on behalf of Ace Space, as well as the contractual and technical safeguards that are in place to protect the data1, 2.


NEW QUESTION # 142
SCENARIO
Please use the following to answer the next QUESTION:
You lead the privacy office for a company that handles information from individuals living in several countries throughout Europe and the Americas. You begin that morning's privacy review when a contracts officer sends you a message asking for a phone call. The message lacks clarity and detail, but you presume that data was lost.
When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating that the vendor improperly shared information about your customers. He called the vendor and confirmed that your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database as promised in the contract. As a result, the vendor has lost control of the data.
The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write. You put their offer on hold and begin to develop the text around the space constraints. You are content to let the vendor's logo be associated with the notification.
The notification explains that your company recently hired a vendor to store information about their most recent experience at St. Sebastian Hospital's Clinic for Infectious Diseases. The vendor did not encrypt the information and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about their information. They simply need to go to your company's website and watch a quick advertisement, then provide their name, email address, and month and year of birth.
You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation, you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their comments back and forth. The consultant who leads the incident-response team notes that it is his first day with the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the day, they vote to proceed with the notification you wrote and use the vendor's postcards.
Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring company with a convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:
1. Send an enrollment invitation to everyone the day after the contract is signed.
2. Enroll someone with just their first name and the last-4 of their national identifier.
3. Monitor each enrollee's credit for two years from the date of enrollment.
4. Send a monthly email with their credit rating and offers for credit-related services at market rates.
5. Charge your company 20% of the cost of any credit restoration.
You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three days later you sit down and document all that went well and all that could have gone better. You put it in a file to reference the next time an incident occurs.
What is the most concerning limitation of the incident-response council?

  • A. You convened it to diffuse blame
  • B. It takes eight hours of emails to come to a decision
  • C. The leader just joined the company as a consultant
  • D. The council has an overabundance of attorneys

Answer: B

Explanation:
This answer is the most concerning limitation of the incident-response council, as it indicates a lack of efficiency, urgency and coordination in handling the incident. It takes eight hours of emails to come to a decision means that the council is wasting valuable time and resources in communicating and resolving the incident, which may result in delayed or inadequate actions, increased harm or impact to the affected individuals or the organization, or non-compliance with any legal or contractual obligations or deadlines.


NEW QUESTION # 143
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 process could most effectively be used to add privacy protections to a new, comprehensive program being developed at Consolidated?

  • A. Privacy by Design.
  • B. Innovation Privacy Standards.
  • C. Privacy Step Assessment.
  • D. Information Security Planning.

Answer: D


NEW QUESTION # 144
What is the main purpose of a privacy program audit?

  • A. To mitigate the effects of a privacy breach.
  • B. To ensure the adequacy of data protection procedures.
  • C. To make decisions on privacy staff roles and responsibilities.
  • D. To justify a privacy department budget increase.

Answer: B


NEW QUESTION # 145
SCENARIO
Please use the following to answer the next QUESTION:
Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green energy market. The current line of products includes wind turbines, solar energy panels, and equipment for geothermal systems. A talented team of developers means that NatGen's line of products will only continue to grow.
With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help manage the company's growth. One recent suggestion has been to combine the legal and security functions of the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in ways that will best suit their needs. She does not want administrative oversight and complex structuring to get in the way of people doing innovative work.
Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use the best possible equipment for electronic storage of customer and employee dat a. She simply needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before the company gets to that stage.
Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can adjust the company privacy policy according to what works best for their particular departments. NatGen's CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of normal business activities.
Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because the employees need no special preparation. They will simply have to document any concerns they hear.
Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique approach.
If Amira and Sadie's ideas about adherence to the company's privacy policy go unchecked, the Federal Communications Commission (FCC) could potentially take action against NatGen for what?

  • A. Failing to institute the hotline.
  • B. Negligence in consistent training.
  • C. Failure to notify of processing.
  • D. Deceptive practices.

Answer: D

Explanation:
If Amira and Sadie's ideas about adherence to the company's privacy policy go unchecked, the Federal Communications Commission (FCC) could potentially take action against NatGen for deceptive practices. This is because the FCC has the authority to enforce Section 5 of the Federal Trade Commission Act, which prohibits unfair or deceptive acts or practices in or affecting commerce. By allowing different departments to use, collect, store, and dispose of customer data in ways that may not be consistent with the company's privacy policy, NatGen may be misleading its customers about how their personal information is protected and used. This could violate the FTC Act and expose NatGen to enforcement actions, fines, and reputational damage. Reference: [FCC Enforcement], [FTC Act], [Privacy Policy]


NEW QUESTION # 146
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