A Review Of Printable CIPM Preparation

NEW QUESTION 1
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. The council has an overabundance of attorneys
• C. It takes eight hours of emails to come to a decision
• D. The leader just joined the company as a consultant

Answer: A

NEW QUESTION 2
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.
To improve the facility's system of data security, Anton should consider following through with the plan for which of the following?

• A. Customer communication.
• B. Employee access to electronic storage.
• C. Employee advisement regarding legal matters.
• D. Controlled access at the company headquarters.

Answer: D

NEW QUESTION 3
Under the General Data Protection Regulation (GDPR), which situation would be LEAST likely to require a Data Protection Impact Assessment (DPIA)?

• A. A health clinic processing its patients’ genetic and health data
• B. The use of a camera system to monitor driving behavior on highways
• C. A Human Resources department using a tool to monitor its employees’ internet activity
• D. An online magazine using a mailing list to send a generic daily digest to marketing emails

Answer: D

NEW QUESTION 4
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.
To determine the steps to follow, what would be the most appropriate internal guide for Ben to review?

• A. Incident Response Plan.
• B. Code of Business Conduct.
• C. IT Systems and Operations Handbook.
• D. Business Continuity and Disaster Recovery Plan.

Answer: B

NEW QUESTION 5
An organization's business continuity plan or disaster recovery plan does NOT typically include what?

• A. Recovery time objectives.
• B. Emergency response guidelines.
• C. Statement of organizational responsibilities.
• D. Retention schedule for storage and destruction of information.

Answer: D

NEW QUESTION 6
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.
What is the most realistic step the organization can take to help diminish liability in the event of another incident?

• A. Requiring the vendor to perform periodic internal audits.
• B. Specifying mandatory data protection practices in vendor contracts.
• C. Keeping the majority of processing activities within the organization.
• D. Obtaining customer consent for any third-party processing of personal data.

Answer: B

NEW QUESTION 7
What is the main reason to begin with 3-5 key metrics during the program development process?

• A. To avoid undue financial costs.
• B. To keep the focus on the main organizational objectives.
• C. To minimize selective data use.
• D. To keep the process limited to as few people as possible.

Answer: C

NEW QUESTION 8
How are individual program needs and specific organizational goals identified in privacy framework development?

• A. By employing metrics to align privacy protection with objectives.
• B. Through conversations with the privacy team.
• C. By employing an industry-standard needs analysis.
• D. Through creation of the business case.

Answer: A

NEW QUESTION 9
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?
Which of the following would be most effectively used as a guide to a systems approach to implementing data protection?

• A. Data Lifecycle Management Standards.
• B. United Nations Privacy Agency Standards.
• C. International Organization for Standardization 9000 Series.
• D. International Organization for Standardization 27000 Series.

Answer: D

NEW QUESTION 10
SCENARIO
Please use the following to answer the next QUESTION:
Edufox has hosted an annual convention of users of its famous e-learning software platform, and over time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into the others, with several thousand attendees enjoying three days of presentations, panel discussions and networking. The convention is the centerpiece of the company's product rollout schedule and a great training opportunity for current users. The sales force also encourages prospective clients to attend to get a better sense of the ways in which the system can be customized to meet diverse needs and understand that when they buy into this system, they are joining a community that feels like family.
This year's conference is only three weeks away, and you have just heard news of a new initiative supporting it: a smartphone app for attendees. The app will support late registration, highlight the featured presentations and provide a mobile version of the conference program. It also links to a restaurant reservation system with the best cuisine in the areas featured. "It's going to be great," the developer, Deidre Hoffman, tells you, "if, that is, we actually get it working!" She laughs nervously but explains that because of the tight time frame she'd been given to build the app, she outsourced the job to a local firm. "It's just three young people," she says, "but they do great work." She describes some of the other apps they have built. When asked how they were selected for this job, Deidre shrugs. "They do good work, so I chose them."
Deidre is a terrific employee with a strong track record. That's why she's been charged to deliver this rushed project. You're sure she has the best interests of the company at heart, and you don't doubt that she's under pressure to meet a deadline that cannot be pushed back. However, you have concerns about the app's handling of personal data and its security safeguards. Over lunch in the break room, you start to talk to her about it, but she quickly tries to reassure you, "I'm sure with your help we can fix any security issues if we have to, but I doubt there'll be any. These people build apps for a living, and they know what they're doing. You worry too much, but that's why you're so good at your job!"
What safeguard can most efficiently ensure that privacy protection is a dimension of relationships with vendors?

• A. Include appropriate language about privacy protection in vendor contracts.
• B. Perform a privacy audit on any vendor under consideration.
• C. Require that a person trained in privacy protection be part of all vendor selection teams.
• D. Do business only with vendors who are members of privacy trade associations.

Answer: C

NEW QUESTION 11
What is one obligation that the General Data Protection Regulation (GDPR) imposes on data processors?

• A. To honor all data access requests from data subjects.
• B. To inform data subjects about the identity and contact details of the controller.
• C. To implement appropriate technical and organizational measures that ensure an appropriate level of security.
• D. To carry out data protection impact assessments in cases where processing is likely to result in high risk to the rights and freedoms of individuals.

Answer: D

NEW QUESTION 12
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.

Answer: A

NEW QUESTION 13
What is a key feature of the privacy metric template adapted from the National Institute of Standards and Technology (NIST)?

• A. It provides suggestions about how to collect and measure data.
• B. It can be tailored to an organization's particular needs.
• C. It is updated annually to reflect changes in government policy.
• D. It is focused on organizations that do business internationally.

Answer: A

NEW QUESTION 14
In addition to regulatory requirements and business practices, what important factors must a global privacy strategy consider?

• A. Monetary exchange.
• B. Geographic features.
• C. Political history.
• D. Cultural norms.

Answer: B

NEW QUESTION 15
An organization is establishing a mission statement for its privacy program. Which of the following statements would be the best to use?

• A. This privacy program encourages cross-organizational collaboration which will stop all data breaches
• B. Our organization was founded in 2054 to reduce the chance of a future disaster like the one that occurred ten years ag
• C. All individuals from our area of the country should be concerned about a future disaste
• D. However, with our privacy program, they should not be concerned about the misuse of their information.
• E. The goal of the privacy program is to protect the privacy of all individuals who support our organizatio
• F. To meet this goal, we must work to comply with all applicable privacy laws.
• G. In the next 20 years, our privacy program should be able to eliminate 80% of our current breache
• H. To do this, everyone in our organization must complete our annual privacy training course and all personally identifiable information must be inventoried.

Answer: C

NEW QUESTION 16
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.

Answer: A

NEW QUESTION 17
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.
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.

Answer: D

NEW QUESTION 18
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