IAPP Updated CIPM Exam Questions and Answers by jayla

SCENARIO

Please use the following to answer the next question

You were recently hired by InStyte Date Corp as a privacy manager to help InStyle Data Corp become compliant with a new data protection law

The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue companies that don t comply with the new law

You are paved with a security manager and tasked with reviewing InStyle Data Corp s current state and advising the business how it can meet the "reasonable and appropriate security" requirement InStyle Data Corp has grown rapidly and has not kept a data inventory or completed a data mapping InStyte Data Corp has also developed security-related policies ad hoc and many have never been implemented The various teams involved in the creation and testing of InStyle Data Corp s products experience significant turnover and do not have well defined roles There's little documentation addressing what personal data is processed by which product and for what purpose

Work needs to begin on this project immediately so that InStyle Data Corp can become compliant by the time the law goes into effect. You and you partner discover that InStyle Data Corp regularly sends files containing sensitive personal data back to its customers through email sometimes using InStyle Data Corp employees personal email accounts. You also team that InStyle Data Corp s privacy and information security teams are not informed of new personal data flows, new products developed by InStyte Data Corp that process personal data, or updates to existing InStyle Data Corp products that may change what or how the personal data is processed until after the product or update has gone have.

Through a review of InStyle Date Corp’s test and development environment logs, you discover InStyle Data Corp sometimes gives login credentials to any InStyle Data Corp employee or contractor who requests them. The test environment only contains dummy data but the development environment contains personal data including Social Security Numbers, hearth ^formation and financial information All credentialed InStyle Data Corp employees and contractors have the ability to after and delete personal data in both environments regardless of their role or what project they are working on.

You and your partner provide a gap assessment citing the issues you spotted, along with recommended remedial actions and a method to measure implementation InStyle Data Corp implements all of the recommended security controls You review the processes roles, controls and measures taken to appropriately protect the personal data at every stop However, you realize there is no plan for monitoring and nothing in place addressing sanctions for violations of the updated policies and procedures InStyle Data Corp pushes back, stating they do not have the resources for such monitoring.

What aspect of the data management life cycle will still be unaddressed it you cannot find the resources to become compliant?

A systems audit uncovered a shared drive folder containing sensitive employee data with no access controls and therefore was available for all employees to view. What is the first step to mitigate further risks?

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.

How could the objection to Spencer's training suggestion be addressed?

If an organization maintains a separate ethics office, to whom would its officer typically report to in order to retain the greatest degree of independence?