Free IAPP CIPM Practice Exams - Page 14 of 23

Question #131

In which situation would a Privacy Impact Assessment (PIA) be the least likely to be required?

A . If a company created a credit-scoring platform five years ago.
B . If a health-care professional or lawyer processed personal data from a patient’s file.
C . If a social media company created a new product compiling personal data to generate user profiles.
D . If an after-school club processed children’s data to determine which children might have food allergies.

Question #132

A new business crafting its privacy policy is struggling with how it will define the term "personal data."

Which of the following should inform this decision?

A . The types of special categories of data being processed.
B . The business’s requirements for storing collected data.
C . The amount of data the business expects to collect.
D . The privacy laws to which the business is subject.

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Question #133

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

A . Implement strong asset control protocols.
B . Implement strong access control measures.
C . Maintain an information security policy.
D . Maintain a vulnerability management program.

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Question #134

Incipia Corporation just trained the last of its 300 employees on their new privacy policies and procedures.

If Incipia wanted to analyze the effectiveness of the training over the next 6 months, which form of trend analysis should they use?

A . Cyclical.
B . Irregular.
C . Statistical.
D . Standard variance.

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Question #135

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 C not data processing C 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 C his uncle’s vice president and longtime confidante C 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.

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

A . To send consistent communication.
B . To shift to electronic communication.
C . To delay communications until local authorities are informed.
D . To consider under what circumstances communication is necessary.

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Correct Answer: D
D

Explanation:

The company’s legal team would most likely recommend Anton to consider under what circumstances communication with customers is necessary after learning of a recent security incident. Communication with customers is an important aspect of data breach response as it can help to mitigate the harm caused by the breach, restore trust and confidence in the company, and comply with legal obligations or best practices. However, communication with customers is not always mandatory or advisable depending on the nature and severity of the breach and the potential impact on the customers7 Therefore, Anton should consult with his legal team and evaluate the following factors before deciding whether to communicate with customers or not:

The type and amount of data involved in the breach and whether it includes personal or sensitive information that could expose the customers to identity theft, fraud, or other harms.

The likelihood and extent of harm that the customers could suffer as a result of the breach and whether they could take any actions to prevent or reduce it.

The legal or contractual obligations that the company has to notify the customers or the relevant authorities about the breach and the applicable laws or regulations that govern the notification process, such as the timing, content, and method of notification.

The potential benefits and risks of communicating with customers, such as enhancing transparency and accountability, providing assistance and remedies, or triggering negative reactions, reputational

damage, or legal claims.

Based on these factors, Anton should determine whether communication with customers is necessary and appropriate in his case. If he decides to communicate with customers, he should follow some best practices, such as:

Communicating as soon as possible after discovering and containing the breach and having sufficient information to share.

Communicating clearly, honestly, and empathetically about what happened, what data was affected, what actions the company has taken or will take, and what steps the customers can or should take. Communicating through multiple channels, such as email, phone, letter, website, or social media, depending on the preferences and expectations of the customers.

Communicating consistently and regularly with updates or follow-ups until the breach is resolved and the customers are satisfied8

Reference: 7: How to Communicate a Data Breach to Customers – U.S. Chamber of Commerce; 8: The do’s and don’ts of communicating a data breach

Question #136

SCENARIO

Please use the following to answer the next QUESTION:

Ben works in the IT department of IgNight, Inc., a company that designs lighting solutions for its clients. Although IgNight’s customer base consists primarily of offices in the US, some individuals have been so impressed by the unique aesthetic and energy-saving design of the light fixtures that they have requested IgNight’s installations in their homes across the globe.

One Sunday morning, while using his work laptop to purchase tickets for an upcoming music festival,

Ben happens to notice some unusual user activity on company files. From a cursory review, all the data still appears to be where it is meant to be but he can’t shake off the feeling that something is not right. He knows that it is a possibility that this could be a colleague performing unscheduled maintenance, but he recalls an email from his company’s security team reminding employees to be on alert for attacks from a known group of malicious actors specifically targeting the industry.

Ben is a diligent employee and wants to make sure that he protects the company but he does not want to bother his hard-working colleagues on the weekend. He is going to discuss the matter with this manager first thing in the morning but wants to be prepared so he can demonstrate his knowledge in this area and plead his case for a promotion.

Going forward, what is the best way for IgNight to prepare its IT team to manage these kind of security events?

A . Tabletop exercises.
B . Update its data inventory.
C . IT security awareness training.
D . Share communications relating to scheduled maintenance.

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Correct Answer: A
A

Explanation:

The best way for IgNight to prepare its IT team to manage these kind of security events is to conduct tabletop exercises. Tabletop exercises are simulated scenarios that test the organization’s ability to respond to security incidents in a realistic and interactive way. Tabletop exercises typically involve: A facilitator who guides the participants through the scenario and injects additional challenges or variables

A scenario that describes a plausible security incident based on real-world threats or past incidents A set of objectives that define the expected outcomes and goals of the exercise

A set of questions that prompt the participants to discuss their roles, responsibilities, actions, decisions, and communications during the incident response process

A feedback mechanism that collects the participants’ opinions and suggestions on how to improve the incident response plan and capabilities

Tabletop exercises help an organization prepare for and deal with security incidents by: Enhancing the awareness and skills of the IT team and other stakeholders involved in incident response

Identifying and addressing the gaps, weaknesses, and challenges in the incident response plan and process

Improving the coordination and collaboration among the IT team and other stakeholders during incident response

Evaluating and validating the effectiveness and efficiency of the incident response plan and process Generating and implementing lessons learned and best practices for incident response

The other options are not as effective or useful as tabletop exercises for preparing the IT team to manage security events. Updating the data inventory is a good practice for maintaining an accurate and comprehensive record of the personal data that the organization collects, processes, stores, shares, or disposes of. However, it does not test or improve the organization’s incident response capabilities or readiness. IT security awareness training is a good practice for educating the IT team and other employees on the basic principles and practices of cybersecurity. However, it does not

simulate or replicate the real-world situations and challenges that the IT team may face during security incidents. Sharing communications relating to scheduled maintenance is a good practice for informing the IT team and other stakeholders of the planned activities and potential impacts on the IT systems and infrastructure. However, it does not prepare the IT team for dealing with unplanned or unexpected security events that may require immediate and coordinated

response.

Reference: CISA Tabletop Exercise Packages; Cybersecurity Tabletop Exercise Examples, Best Practices, and Considerations; Six Tabletop Exercises to Help Prepare Your Cybersecurity Team

Question #137

Under the General Data Protection Regulation (GDPR), what must be included in a written agreement between the controller and processor in relation to processing conducted on the controller’s behalf?

A . An obligation on the processor to report any personal data breach to the controller within 72 hours.
B . An obligation on both parties to report any serious personal data breach to the supervisory authority.
C . An obligation on both parties to agree to a termination of the agreement if the other party is responsible for a personal data breach.
D . An obligation on the processor to assist the controller in complying with the controller’s obligations to notify the supervisory authority about personal data breaches.

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Question #138

Which is TRUE about the scope and authority of data protection oversight authorities?

A . The Office of the Privacy Commissioner (OPC) of Canada has the right to impose financial sanctions on violators.
B . All authority in the European Union rests with the Data Protection Commission (DPC).
C . No one agency officially oversees the enforcement of privacy regulations in the United States.
D . The Asia-Pacific Economic Cooperation (APEC) Privacy Frameworks require all member nations to designate a national data protection authority.

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Question #139

For an organization that has just experienced a data breach, what might be the least relevant metric for a company’s privacy and governance team?

A . The number of security patches applied to company devices.
B . The number of privacy rights requests that have been exercised.
C . The number of Privacy Impact Assessments that have been completed.
D . The number of employees who have completed data awareness training.

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Question #140

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?

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.

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