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質問 # 117
What should a privacy professional keep in mind when selecting which metrics to collect?
- A. Metrics should reveal strategies for increasing company earnings.
- B. The number of metrics should be limited at first.
- C. A variety of metrics should be collected before determining their specific functions.
- D. Metrics should be reported to the public.
正解：B
解説：
A privacy professional should keep in mind that the number of metrics should be limited at first when selecting which metrics to collect. Metrics are quantitative measures that help evaluate the performance and effectiveness of a privacy program. However, collecting too many metrics can be overwhelming, confusing, and costly. Therefore, a privacy professional should start with a few key metrics that are relevant, meaningful, actionable, and aligned with the organization's privacy goals and priorities. These metrics can be refined and expanded over time as the privacy program matures and evolves. References: [Privacy Metrics], [Measuring Privacy Program Effectiveness]
質問 # 118
In a sample metric template, what does "target" mean?
- A. The threshold for a satisfactory rating
- B. The frequency at which the data is sampled
- C. The suggested volume of data to collect
- D. The percentage of completion
正解：A
解説：
In a sample metric template, the target is the threshold for a satisfactory rating. It is the desired or expected value for the metric that indicates a successful performance or outcome. For example, if the metric is the percentage of employees who completed privacy training, the target could be 90% or higher. Reference: IAPP CIPM Study Guide, page 22.
質問 # 119
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. Share communications relating to scheduled maintenance.
- B. IT security awareness training.
- C. Update its data inventory.
- D. Tabletop exercises.
正解：D
質問 # 120
If your organization has a recurring issue with colleagues not reporting personal data breaches, all of the following are advisable to do EXCEPT?
- A. Provide role-specific training to areas where breaches are happening so they are more aware.
- B. Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.
- C. Communicate to everyone that breaches must be reported and how they should be reported.
- D. Carry out a root cause analysis on each breach to understand why the incident happened.
正解：B
解説：
Distributing a phishing exercise to all employees is not advisable to do if your organization has a recurring issue with colleagues not reporting personal data breaches. A phishing exercise is a simulated attack that tests the awareness and response of employees to malicious emails that attempt to obtain sensitive information or compromise systems. While phishing exercises can be useful to train employees on how to recognize and avoid phishing attacks, they are not directly related to the issue of reporting personal data breaches. The other options are more appropriate to address the root cause of the issue, communicate the expectations and procedures for reporting breaches, and provide specific training to areas where breaches are happening1, 2. References: CIPM - International Association of Privacy Professionals, Free CIPM Study Guide - International Association of Privacy Professionals
質問 # 121
SCENARIO
Please use the following to answer the next question:
For 15 years, Albert has worked at Treasure Box - a mail order company in the United States (U.S.) that used to sell decorative candles around the world, but has recently decided to limit its shipments to customers in the
48 contiguous states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not being promoted, coupled with his recent interest in issues of privacy protection, have motivated Albert to be an agent of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives aware of lapses in the company's privacy program. He feels certain he will be rewarded with a promotion for preventing negative consequences resulting from the company's outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful way to measure Treasure Box's ability to protect personal data. Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company's commitment to the security of customer and employee personal data against external threats. However, Albert worries about the high turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two recent security incidents. The company has responded to the incidents with internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help the company recover.
He knows there is at least one incident the public in unaware of, although Albert does not know the details. He believes the company's insistence on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company's recent business maneuvers will also impress the interviewers. For example, Albert is aware of the company's intention to acquire a medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.
On which of the following topics does Albert most likely need additional knowledge?
- A. The necessary maturity level of privacy programs
- B. The role of privacy in retail companies
- C. The possibility of delegating responsibilities related to privacy
- D. The requirements for a managerial position with privacy protection duties
正解：C
質問 # 122
All of the following changes will likely trigger a data inventory update EXCEPT?
- A. Acquisition of a new subsidiary.
- B. Onboarding of a new vendor.
- C. Passage of a new privacy regulation.
- D. Outsourcing the Customer Relationship Management (CRM) function.
正解：C
解説：
Explanation
All of the changes listed will likely trigger a data inventory update except for the passage of a new privacy regulation. A data inventory is a record of all personal data that an organization collects, processes, stores, shares, or disposes of. A data inventory helps an organization understand what types of personal data it holds, where it comes from, where it goes, and how it is protected. A data inventory should be updated regularly to reflect any changes in the organization's data processing activities or practices. Some examples of changes that would trigger a data inventory update are outsourcing a business function, acquiring a new subsidiary, or onboarding a new vendor. These changes may involve new sources or destinations of personal data, new purposes or categories of processing, new security measures or risks, or new contractual agreements or obligations. The passage of a new privacy regulation may not trigger a data inventory update unless it affects the organization's existing data processing activities or practices. However, it may trigger a compliance assessment or gap analysis to determine if the organization needs to make any adjustments to its privacy program or policies to meet the new legal requirements. References: Data Inventory Hub; Data Inventory:
What It Is & How To Create One
質問 # 123
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!" Since it is too late to restructure the contract with the vendor or prevent the app from being deployed, what is the best step for you to take next?
- A. Implement a more comprehensive suite of information security controls than the one used by the vendor.
- B. Insist on an audit of the vendor's privacy procedures and safeguards.
- C. Develop security protocols for the vendor and mandate that they be deployed.
- D. Ask the vendor for verifiable information about their privacy protections so weaknesses can be identified.
正解：D
解説：
This answer is the best step to take next, as it can help you to assess the current state of the vendor's privacy practices and determine if they meet the organization's standards and expectations, as well as the applicable laws and regulations. Asking the vendor for verifiable information about their privacy protections can include requesting documentation, evidence or demonstration of how they collect, use, store, protect, share and dispose of personal data, what policies and procedures they have in place, what technical and organizational measures they implement, what certifications or audits they have obtained or undergone, and how they handle any privacy incidents or breaches. Based on this information, you can identify any weaknesses or gaps in the vendor's privacy protections and recommend or require any improvements or corrections before the app is deployed. References: IAPP CIPM Study Guide, page 82; ISO/IEC 27002:2013, section 15.1.2
質問 # 124
An organization's business continuity plan or disaster recovery plan does NOT typically include what?
- A. Recovery time objectives.
- B. Emergency response guidelines.
- C. Retention schedule for storage and destruction of information.
- D. Statement of organizational responsibilities.
正解：C
解説：
An organization's business continuity plan or disaster recovery plan does not typically include a retention schedule for storage and destruction of information. A retention schedule is a document that specifies how long different types of information should be kept by an organization before they are disposed of or destroyed.
A retention schedule is usually based on legal, regulatory, operational, historical, or archival requirements. A retention schedule is part of an organization's information governance or records management policy, not its business continuity or disaster recovery plan.
A business continuity plan (BCP) is a document that outlines how an organization will continue its critical functions and operations in the event of a disruption or disaster. A BCP usually includes:
* Contact information and service level agreements (SLAs) for key personnel, stakeholders, providers, backup site operators, etc.
* Business impact analysis (BIA) that identifies the potential impacts of disruption on all aspects of the business, such as financial, legal, reputational, etc.
* Risk assessment that identifies and evaluates the likelihood and severity of various threats and vulnerabilities that could cause disruption or disaster.
* Identification of critical functions that are essential for the survival and recovery of the business.
* Communications plan that specifies how to communicate with internal and external parties during and after a disruption or disaster.
* Testing plan that specifies how to test and update the BCP regularly to ensure its effectiveness and validity.
A disaster recovery plan (DRP) is a document that outlines how an organization will restore its IT systems, data, applications, and infrastructure in the event of a disruption or disaster. A DRP usually includes:
* Recovery time objectives (RTOs) that specify how quickly each IT system or service needs to be restored after a disruption or disaster.
* Recovery point objectives (RPOs) that specify how much data loss is acceptable for each IT system or service after a disruption or disaster.
* Emergency response guidelines that specify how to respond to and contain a disruption or disaster, such as activating the DRP, declaring a disaster, notifying the stakeholders, etc.
* Statement of organizational responsibilities that specifies who is responsible for what tasks and roles during and after a disruption or disaster, such as initiating the DRP, executing the recovery procedures, restoring the IT systems or services, etc.
* Recovery procedures that specify how to recover each IT system or service from backup sources, such as backup tapes, disks, cloud services, etc.
* Testing plan that specifies how to test and update the DRP regularly to ensure its effectiveness and validity. References: [Business Continuity Plan (BCP) Definition]; [Disaster Recovery Plan (DRP) Definition]
質問 # 125
Which most accurately describes the reasons an organization will conduct a PIA?
- A. To establish an inventory of its data processing activities in compliance with Article 30 of the GDPR.
- B. To analyze the impact of an incident response and determine next steps.
- C. To assess an organization's compliance with applicable laws, regulations, standards, and internal procedures.
- D. To identify and reduce the privacy risks to individuals at the commencement of a project.
正解：D
解説：
Step-by-Step Comprehensive Detailed Explanation with All Information Privacy Manager CIPM Study Guide References A Privacy Impact Assessment (PIA) is conducted to identify and mitigate privacy risks. Let's review the options:
A). To assess compliance with applicable laws, regulations, standards, and procedures:
This describes an audit or compliance assessment, not the primary purpose of a PIA.
B). To establish an inventory of its data processing activities in compliance with Article 30 of the GDPR:
This aligns with the GDPR requirement for maintaining records of processing activities (ROPA), but it is not the primary focus of a PIA.
C). To identify and reduce the privacy risks to individuals at the commencement of a project:
This is the core purpose of a PIA, which aims to evaluate and minimize risks to individuals' data privacy early in a project's lifecycle.
D). To analyze the impact of an incident response and determine next steps:
This describes a post-breach analysis, not the purpose of a PIA.
CIPM Study Guide References:
Privacy Program Operational Life Cycle - "Assess" phase emphasizes PIAs as tools for identifying and mitigating risks to personal data.
GDPR compliance guidance also identifies PIAs as necessary for high-risk processing activities under Article
35.
質問 # 126
SCENARIO
Please use the following lo answer the next question:
You are the privacy manager within the privacy office of a National Forest Parks and Recreation Department.
While having lunch with a colleague from the IT division, you learn that the IT director has put out a request for proposal (RFP) which calls for a system that collects the personal data of park attendees.
You consult with a few other colleagues in IT and learn that the RFP is worded such that it leaves it to the vendors to demonstrate what information they would collect from people who enter parks anywhere in the country, either in a vehicle or on foot. A partial list of the information collected includes:
* personal identifiers such as name, address, age, gender;
* vehicle registration information:
* facial images of park attendees;
* health information (e.g.. physical disabilities, use of mobility devices) The stated purpose of the RFP is to:
"Improve the National Forest. Parks, and Recreation Department's ability to track and monitor service usage thereby Increasing the robustness of our customer data and to improve service offerings.'' Companies have already started submitting proposals for software solutions that address these information gathering practices. There is only one week left before the RFP closes.
The IT department has put together an RFP evaluation team but no one from the privacy office has been a Dart of the RFP ud to this point. This occurred deposite the fact....
Which of the following is the least important privacy consideration associated with assessing data when implementing a large-scale project like this?
- A. Standardization of privacy safeguards on a national scale.
- B. Identifying operational risks associated with data storage, access and disposal.
- C. Classification of the types of personal information collected by the system
- D. Third-party vendor assessment to determine how well privacy practices of vendors align with your organization's practices.
正解：C
質問 # 127
An organization is establishing a mission statement for its privacy program. Which of the following statements would be the best to use?
- A. The goal of the privacy program is to protect the privacy of all individuals who support our organization. To meet this goal, we must work to comply with all applicable privacy laws.
- B. In the next 20 years, our privacy program should be able to eliminate 80% of our current breaches. To do this, everyone in our organization must complete our annual privacy training course and all personally identifiable information must be inventoried.
- C. Our organization was founded in 2054 to reduce the chance of a future disaster like the one that occurred ten years ago. All individuals from our area of the country should be concerned about a future disaster. However, with our privacy program, they should not be concerned about the misuse of their information.
- D. This privacy program encourages cross-organizational collaboration which will stop all data breaches
正解：A
解説：
An organization's mission statement for its privacy program should be concise, clear, and realistic. It should communicate the purpose and scope of the program, as well as the values and principles that guide it. It should also reflect the organization's culture and identity, and align with its strategic objectives. Out of the four options, statement C is the best one to use because it expresses the goal of protecting the privacy of all individuals who support the organization, and acknowledges the need to comply with all applicable privacy laws. The other statements are either too vague, too specific, too ambitious, or too irrelevant for a mission statement. References: IAPP CIPM Study Guide, page 18.
質問 # 128
SCENARIO
Please use the following to answer the next QUESTION:
For 15 years, Albert has worked at Treasure Box - a mail order company in the United States (U.S.) that used to sell decorative candles around the world, but has recently decided to limit its shipments to customers in the 48 contiguous states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not being promoted, coupled with his recent interest in issues of privacy protection, have motivated Albert to be an agent of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives aware of lapses in the company's privacy program. He feels certain he will be rewarded with a promotion for preventing negative consequences resulting from the company's outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful way to measure Treasure Box's ability to protect personal dat a. Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company's commitment to the security of customer and employee personal data against external threats. However, Albert worries about the high turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two recent security incidents. The company has responded to the incidents with internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help the company recover. He knows there is at least one incident the public in unaware of, although Albert does not know the details. He believes the company's insistence on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company's recent business maneuvers will also impress the interviewers. For example, Albert is aware of the company's intention to acquire a medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.
What is one important factor that Albert fails to consider regarding Treasure Box's response to their recent security incident?
- A. What the nature of the data is
- B. How data at the company is collected
- C. How long data at the company is kept
- D. Who has access to the data
正解：A
解説：
This answer is an important factor that Albert fails to consider, as it can affect the legal and ethical obligations and implications of the company's response to the security incident, as well as the potential impact and harm to the individuals whose data is involved. The nature of the data refers to the type, category, sensitivity and value of the data that is collected, processed and stored by the company, such as personal, financial, health, biometric or behavioral data. Depending on the nature of the data, the company may have different requirements or restrictions for notifying, reporting or disclosing the security incident to the relevant authorities, customers, partners or stakeholders, as well as for mitigating or compensating the effects of the incident. For example, if the data is considered sensitive or confidential, such as health or medical information, the company may have a higher duty of care and a stricter obligation to protect and secure the data, as well as to inform and assist the individuals whose data is compromised.
質問 # 129
Training and awareness metrics in a privacy program are necessary to?
- A. Demonstrate compliance with regulations.
- B. Educate customers on the organization's data practices.
- C. Identify data breaches.
- D. Implement privacy policies.
正解：A
質問 # 130
Why were the nongovernmental privacy organizations, Electronic Frontier Foundation (EFF) and Electronic Privacy Information Center (EPIC), established?
- A. To promote consumer confidence in the Internet industry.
- B. To improve the user experience during online shopping.
- C. To promote security on the Internet through strong encryption.
- D. To protect civil liberties and raise consumer awareness.
正解：D
解説：
The nongovernmental privacy organizations, Electronic Frontier Foundation (EFF) and Electronic Privacy Information Center (EPIC), were established to protect civil liberties and raise consumer awareness in the digital age. Both organizations are public interest research centers that focus on emerging privacy and civil liberties issues and advocate for the protection of privacy, freedom of expression, and democratic values in the information age12 They conduct policy research, public education, litigation, publications, and advocacy to promote privacy rights and challenge threats to privacy from governments, corporations, or other actors12 They also monitor and participate in the development of laws, regulations, standards, and technologies that affect privacy and civil liberties12 Reference: 1: About EPIC; 2: About EFF
質問 # 131
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?
- A. Check access logs to see who accessed the folder.
- B. Notify legal counsel of a privacy incident.
- C. Restrict access to the folder.
- D. Notify all employees whose information was contained in the file.
正解：C
解説：
Explanation
The first step to mitigate further risks when a systems audit uncovers a shared drive folder containing sensitive employee data with no access controls is to restrict access to the folder. This can be done by implementing appropriate access controls, such as user authentication, role-based access, and permissions, to ensure that only authorized individuals can view and access the sensitive data.
質問 # 132
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 both parties to report any serious personal data breach to the supervisory authority
- B. An obligation on the processor to report any personal data breach to the controller within 72 hours,
- 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.
正解：D
解説：
Explanation
Under the GDPR, a written agreement between the controller and processor in relation to processing conducted on the controller's behalf must include 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.
This is one of the requirements under Article 28(3)(f) of the GDPR, which specifies the minimum content of such an agreement. The other options are not required by the GDPR, although they may be agreed upon by the parties as additional terms. References: GDPR, Article 28(3)(f).
質問 # 133
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