CIPM Online Practice Questions and Answers

Which of the following actions is NOT required during a data privacy diligence process for Merger and Acquisition (MandA) deals?

A. Revise inventory of applications that house personal data and data mapping.

B. Update business processes to handle Data Subject Requests (DSRs).

C. Compare the original use of personal data to post-merger use.

D. Perform a privacy readiness assessment before the deal.

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 step in the system development process did Manasa skip?

A. Obtain express written consent from users of the Handy Helper regarding marketing.

B. Work with Sanjay to review any necessary privacy requirements to be built into the product.

C. Certify that the Handy Helper meets the requirements of the EU-US Privacy Shield Framework.

D. Build the artificial intelligence feature so that users would not have to input sensitive information into the Handy Helper.

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

A. His initiative to achieve regulatory compliance.

B. His intention to transition to electronic storage.

C. His objective for zero loss of personal information.

D. His intention to send notice letters to customers and employees.

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?

A. First-party audit.

B. Second-party audit.

C. Third-party audit.

D. Fourth-party audit.

Which of the following best supports implementing controls to bring privacy policies into effect?

A. The internal audit department establishing the audit controls which test for policy effectiveness.

B. The legal department or outside counsel conducting a thorough review of the privacy program and policies.

C. The Chief Information Officer as part of the Senior Management Team creating enterprise privacy policies to ensure controls are available.

D. The information technology (IT) group supporting and enhancing the privacy program and privacy policy by developing processes and controls.

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. Privacy Step Assessment.

C. Information Security Planning.

D. Innovation Privacy Standards.

If your organization has a recurring issue with colleagues not reporting personal data breaches, all of the following are advisable to do EXCEPT?

A. Review reporting activity on breaches to understand when incidents are being reported and when they are not to improve communication and training.

B. Improve communication to reinforce to everyone that breaches must be reported and how they should be reported.

C. Provide role-specific training to areas where breaches are happening so they are more aware.

D. Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.

What should a privacy professional keep in mind when selecting which metrics to collect?

A. Metrics should be reported to the public.

B. The number of metrics should be limited at first.

C. Metrics should reveal strategies for increasing company earnings.

D. A variety of metrics should be collected before determining their specific functions.

What is the function of the privacy operational life cycle?

A. It establishes initial plans for privacy protection and implementation

B. It allows the organization to respond to ever-changing privacy demands

C. It ensures that outdated privacy policies are retired on a set schedule

D. It allows privacy policies to mature to a fixed form

Training and awareness metrics in a privacy program are necessary to?

A. Identify data breaches.

B. Implement privacy policies.

C. Demonstrate compliance with regulations.

D. Educate customers on the organization's data practices.