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CIPM認定の有効な試験問題集解答学習ガイド！（最新の275問題) [Q88-Q113]

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CIPM認定の有効な試験問題集解答学習ガイド！（最新の275問題)

CIPM問題集で時間限定！無料アクセスせよ


IAPP CIPM（認定情報プライバシーマネージャー）認定試験は、組織内のプライバシーポリシーと慣行を管理するためのスキルと知識を個人に提供するグローバルに認められた認定です。この認定は、専門家がグローバル基準と規制要件を満たすプライバシープログラム、ポリシー、および手順を開発および実施するのを支援するように設計されています。

 

質問 # 88
A Human Resources director at a company reported that a laptop containing employee payroll data was lost on the train. Which action should the company take IMMEDIATELY?

  • A. Wipe the hard drive remotely
  • B. Report the theft to the senior management
  • C. Report the theft to law enforcement
  • D. Perform a multi-factor risk analysis

正解：D

解説：
Explanation
The company should perform a multi-factor risk analysis immediately after discovering the loss of the laptop containing employee payroll data. A multi-factor risk analysis is a process of assessing the potential impact and likelihood of a data breach, taking into account various factors such as the nature, scope, context, and purpose of the processing, the type and severity of the harm that may result from the breach, the number and categories of data subjects and personal data affected, the measures taken to mitigate the risk, and any relevant legal obligations or codes of conduct. A multi-factor risk analysis can help the company determine whether the breach poses a high risk to the rights and freedoms of the data subjects, and whether it needs to notify them and/or the relevant supervisory authority without undue delay, as required by Article 33 and 34 of the GDPR1.
A multi-factor risk analysis can also help the company identify the root cause of the breach, evaluate the effectiveness of its existing security measures, and implement appropriate corrective actions to prevent or minimize similar incidents in the future.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B:
Protecting Personal Information, Subsection 2: Data Breach Incident Planning and Management2
* CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management3
* CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management4
* CIPM Practice Exam (2021), Question 1285
* GDPR Article 33 and 341


質問 # 89
What is most critical when outsourcing data destruction service?

  • A. Conduct an annual in-person audit of the provider's facilities.
  • B. Confirm data destruction must be done on-site.
  • C. Obtain a certificate of data destruction.
  • D. Ensure that they keep an asset inventory of the original data.

正解：C

解説：
Obtaining a certificate of data destruction is the most critical step when outsourcing data destruction service.
Data destruction is the process of permanently erasing or destroying personal information from electronic devices or media so that it cannot be recovered or reconstructed. Data destruction is an important part of data protection and retention policies, as it helps prevent unauthorized access, disclosure, or misuse of personal information that is no longer needed or relevant. Outsourcing data destruction service can be convenient and cost-effective for an organization that does not have the resources or expertise to perform it in-house.
However, outsourcing also involves transferring personal information to a third-party provider that may not have the same level of security or accountability as the organization. Therefore, obtaining a certificate of data destruction from the provider is essential to verify that the data destruction has been performed according to the agreed standards and specifications, and that no copies or backups have been retained by the provider. A certificate of data destruction should include information such as: the date and time of the data destruction; the method and level of the data destruction; the serial numbers or identifiers of the devices or media; the name and signature of the person who performed the data destruction; and any relevant laws or regulations that apply to the data destruction.
References:
CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle Section B:
Protecting Personal Information Subsection 4: Data Retention
CIPM Study Guide (2021), Chapter 8: Protecting Personal Information Section 8.4: Data Retention CIPM Textbook (2019), Chapter 8: Protecting Personal Information Section 8.4: Data Retention CIPM Practice Exam (2021), Question 149


質問 # 90
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.
In consideration of the company's new initiatives, which of the following laws and regulations would be most appropriate for Albert to mention at the interview as a priority concern for the privacy team?

  • A. Health Insurance Portability and Accountability Act (HIPAA)
  • B. The Telephone Consumer Protection Act (TCPA)
  • C. The General Data Protection Regulation (GDPR)
  • D. Gramm-Leach-Bliley Act (GLBA)

正解：A

解説：
The most appropriate law for Albert to mention at the interview as a priority concern for the privacy team is the Health Insurance Portability and Accountability Act (HIPAA). HIPAA is a US federal law that establishes national standards for the protection of sensitive patient health information. HIPAA regulates the use, disclosure, and safeguarding of protected health information (PHI), which is any information that can identify a patient or relate to their health or health care services. HIPAA applies to covered entities, such as health plans, health care providers, and health care clearinghouses, and their business associates, such as vendors, contractors, or partners that access or handle PHI on their behalf. HIPAA requires covered entities and business associates to comply with the Privacy Rule, which sets forth the rights of individuals and the obligations of entities regarding PHI; the Security Rule, which specifies the administrative, technical, and physical safeguards to ensure the confidentiality, integrity, and availability of PHI; and the Breach Notification Rule, which requires the notification of individuals, HHS, and in some cases the media, in the event of a breach of unsecured PHI.
Since Treasure Box intends to acquire a medical supply company in the coming weeks, it is likely that it will become a business associate of some covered entities under HIPAA. Therefore, it will need to ensure that its privacy program is compliant with HIPAA requirements and that it has appropriate agreements and safeguards in place to protect PHI. Albert should mention this as a priority concern for the privacy team and demonstrate his awareness and knowledge of HIPAA.
The other options are not as relevant or important as HIPAA for Treasure Box's new initiatives. The Gramm-Leach-Bliley Act (GLBA) is a US federal law that requires financial institutions to explain how they share and protect their customers' non-public personal information. It also repealed the Glass-Steagall Act of 1933, which prohibited commercial banks from offering investment and insurance services. GLBA does not apply to Treasure Box since it is not a financial institution. The General Data Protection Regulation (GDPR) is an EU law that provides a comprehensive framework for the protection of personal data of individuals in the EU. It imposes strict obligations and rights on data controllers and processors regarding the collection, use, disclosure, and security of personal data. GDPR does not apply to Treasure Box since it has recently decided to limit its shipments to customers in the 48 contiguous states of the US. The Telephone Consumer Protection Act (TCPA) is a US federal law that restricts telemarketing calls, text messages, faxes, and prerecorded messages. It requires prior express consent from consumers before making such communications and provides consumers with the right to opt out or revoke their consent. TCPA may apply to Treasure Box since it engages in direct phone marketing, but it is not a new initiative or a priority concern for the privacy team. Reference: HIPAA; GLBA; GDPR; [TCPA]


質問 # 91
Your company wants to convert paper records that contain customer personal information into electronic form, upload the records into a new third-party marketing tool and then merge the customer personal information in the marketing tool with information from other applications.
As the Privacy Officer, which of the following should you complete to effectively make these changes?

  • A. A Record of Authority.
  • B. A Privacy Impact Assessment (PIA).
  • C. A Personal Data Inventory.
  • D. A Privacy Threshold Analysis (PTA).

正解：B

解説：
A Privacy Impact Assessment (PIA) is a process that helps an organization identify and evaluate the potential privacy risks and impacts of a new or existing project, program, system, or service that involves the collection, use, disclosure, or retention of personal information. A PIA also helps an organization identify and implement appropriate measures to mitigate or eliminate those risks and impacts, and ensure compliance with applicable privacy laws, regulations, and standards. A PIA should be completed to effectively make changes that involve customer personal information, such as converting paper records into electronic form, uploading the records into a new third-party marketing tool, and merging the customer personal information in the marketing tool with information from other applications. A PIA can help an organization assess the necessity, proportionality, and legality of the proposed changes, as well as the potential privacy risks to the customers and the organization, such as unauthorized access, disclosure, modification, or loss of personal information, identity theft, fraud, reputational damage, or legal liability. A PIA can also help an organization implement appropriate measures to mitigate or eliminate those risks, such as data minimization, encryption, anonymization, pseudonymization, consent management, access control, security safeguards, contractual clauses, data protection impact assessments (DPIAs), data subject rights, breach notification procedures, and privacy policies.
Reference:
CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section C: Monitoring and Managing Program Performance Subsection 1: Privacy Impact Assessments1 CIPM Study Guide (2021), Chapter 9: Monitoring and Managing Program Performance Section 9.1: Privacy Impact Assessments2 CIPM Textbook (2019), Chapter 9: Monitoring and Managing Program Performance Section 9.1: Privacy Impact Assessments3 CIPM Practice Exam (2021), Question 1464


質問 # 92
Which of the following is TRUE about the Data Protection Impact Assessment (DPIA) process as required under the General Data Protection Regulation (GDPR)?

  • A. The DPIA is required if the processing activity entails risk to the rights and freedoms of an EU individual.
  • B. The DPIA result must be reported to the corresponding supervisory authority.
  • C. The DPIA must include a description of the proposed processing operation and its purpose.
  • D. The DPIA report must be published to demonstrate the transparency of the data processing.

正解：C

解説：
The statement that is true about the Data Protection Impact Assessment (DPIA) process as required under the General Data Protection Regulation (GDPR) is that the DPIA must include a description of the proposed processing operation and its purpose. According to Article 35(7) of the GDPR, a DPIA shall contain at least:
* "a systematic description of the envisaged processing operations and the purposes of the processing";
* "an assessment of the necessity and proportionality of the processing operations in relation to the purposes";
* "an assessment of the risks to the rights and freedoms of data subjects";
* "the measures envisaged to address the risks";
* "safeguards", "security measures";
* "mechanisms to ensure the protection of personal data";
* "to demonstrate compliance with this Regulation taking into account the rights and legitimate interests of data subjects and other persons concerned"5 Therefore, a DPIA must include a description of what data processing activities are planned and why they are needed as part of its content. This helps to provide a clear overview of the processing operation and its objectives as well as to assess its necessity and proportionality in relation to its purposes6 References: 5:
[General Data Protection Regulation (GDPR) - Official Legal Text], Article 35(7); 6: Data protection impact assessments | ICO


質問 # 93
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 dat a. 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 consider under what circumstances communication is necessary.
  • B. To shift to electronic communication.
  • C. To delay communications until local authorities are informed.
  • D. To send consistent communication.

正解：A

解説：
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


質問 # 94
In which situation would a Privacy Impact Assessment (PIA) be the least likely to be required?

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

正解：B

解説：
A Privacy Impact Assessment (PIA) is a process that helps to identify and mitigate the privacy risks of a project or activity that involves personal data. A PIA is usually required when there is a new or significant change in the way personal data is collected, used, or disclosed. Therefore, a PIA would be the least likely to be required if a company created a credit-scoring platform five years ago, as this would not be a new or significant change. The other situations involve new or changed processing of personal data that could have privacy impacts, such as sensitive data (health or children's data), profiling data (user profiles), or large-scale data (patient's file). Reference: CIPM Study Guide, page 30; Guide to undertaking privacy impact assessments.


質問 # 95
SCENARIO
Please use the following to answer the next QUESTION:
Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green energy market. The current line of products includes wind turbines, solar energy panels, and equipment for geothermal systems. A talented team of developers means that NatGen's line of products will only continue to grow.
With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help manage the company's growth. One recent suggestion has been to combine the legal and security functions of the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in ways that will best suit their needs. She does not want administrative oversight and complex structuring to get in the way of people doing innovative work.
Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use the best possible equipment for electronic storage of customer and employee dat a. She simply needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before the company gets to that stage.
Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can adjust the company privacy policy according to what works best for their particular departments. NatGen's CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of normal business activities.
Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because the employees need no special preparation. They will simply have to document any concerns they hear.
Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique approach.
What Data Lifecycle Management (DLM) principle should the company follow if they end up allowing departments to interpret the privacy policy differently?

  • A. Create categories to reflect degrees of data importance.
  • B. Arrange for official credentials for staff members.
  • C. Prove the authenticity of the company's records.
  • D. Adequately document reasons for inconsistencies.

正解：D

解説：
If the company ends up allowing departments to interpret the privacy policy differently, they should follow the Data Lifecycle Management (DLM) principle of adequately documenting reasons for inconsistencies. This principle requires that data should be accurate, complete, and consistent throughout its lifecycle and that any deviations or discrepancies should be justified and recorded1 This would help the company to maintain data quality and integrity, as well as to demonstrate accountability and compliance with data protection regulations2 The other options are not DLM principles that the company should follow if they allow departments to interpret the privacy policy differently. Proving the authenticity of the company's records is a principle related to data preservation and archiving, not data interpretation3 Arranging for official credentials for staff members is a principle related to data access and security, not data interpretation4 Creating categories to reflect degrees of data importance is a principle related to data classification and retention, not data interpretation5 Reference: 1: Data Lifecycle Management: A Complete Guide | Splunk; 2: Data Lifecycle Management | IBM; 3: Data Preservation | Digital Preservation Handbook; 4: Data Access Management Best Practices | Smartsheet; 5: Data Classification: What It Is And How To Do It | Varonis


質問 # 96
Which of the following is TRUE about the Data Protection Impact Assessment (DPIA) process as required under the General Data Protection Regulation (GDPR)?

  • A. The DPIA is required if the processing activity entails risk to the rights and freedoms of an EU individual.
  • B. The DPIA result must be reported to the corresponding supervisory authority.
  • C. The DPIA must include a description of the proposed processing operation and its purpose.
  • D. The DPIA report must be published to demonstrate the transparency of the data processing.

正解：C

解説：
Explanation
The statement that is true about the Data Protection Impact Assessment (DPIA) process as required under the General Data Protection Regulation (GDPR) is that the DPIA must include a description of the proposed processing operation and its purpose. According to Article 35(7) of the GDPR, a DPIA shall contain at least:
* "a systematic description of the envisaged processing operations and the purposes of the processing";
* "an assessment of the necessity and proportionality of the processing operations in relation to the purposes";
* "an assessment of the risks to the rights and freedoms of data subjects";
* "the measures envisaged to address the risks";
* "safeguards", "security measures";
* "mechanisms to ensure the protection of personal data";
* "to demonstrate compliance with this Regulation taking into account the rights and legitimate interests of data subjects and other persons concerned"5 Therefore, a DPIA must include a description of what data processing activities are planned and why they are needed as part of its content. This helps to provide a clear overview of the processing operation and its objectives as well as to assess its necessity and proportionality in relation to its purposes6 References: 5:
[General Data Protection Regulation (GDPR) - Official Legal Text], Article 35(7); 6: Data protection impact assessments | ICO


質問 # 97
The General Data Protection Regulation (GDPR) specifies fines that may be levied against data controllers for certain infringements. Which of the following will be subject to administrative fines of up to 10 000 000 EUR, or in the case of an undertaking, up to 2% of the total worldwide annual turnover of the preceding financial year?

  • A. Failure to implement technical and organizational measures to ensure data protection is enshrined by design and default
  • B. Failure to process personal information in a manner compatible with its original purpose
  • C. Failure to demonstrate that consent was given by the data subject to the processing of their personal data where it is used as the basis for processing
  • D. Failure to provide the means for a data subject to rectify inaccuracies in personal data

正解：C

解説：
Explanation/Reference: https://gdpr-info.eu/art-8-gdpr/


質問 # 98
Under the GDPR. when the applicable lawful basis for the processing of personal data is a legal obligation with which the controller must comply. which right can the data subject exercise?

  • A. Right to restriction.
  • B. Right to data portability.
  • C. Right to erasure.
  • D. Right to withdraw consent.

正解：A

解説：
Explanation
Under the GDPR, when the applicable lawful basis for the processing of personal data is a legal obligation with which the controller must comply, the data subject can exercise the right to restriction. This means that the data subject can request the controller to limit the processing of their personal data in certain circumstances, such as when they contest the accuracy or lawfulness of the processing. The other rights are not applicable in this case, as they are either dependent on consent (right to withdraw consent and right to data portability) or subject to exceptions (right to erasure). References: GDPR, Articles 6(1), 18, 21(1).


質問 # 99
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?

  • A. By customizing training based on length of employee tenure.
  • B. By requiring training only on an as-needed basis.
  • C. By offering alternative delivery methods for trainings.
  • D. By introducing a system of periodic refresher trainings.

正解：C

解説：
Explanation
This answer is the best way to address the objection to Spencer's training suggestion, as it can provide flexibility and convenience for employees who work in different locations or have different schedules.
Alternative delivery methods for trainings can include online courses, webinars, podcasts, videos or self-paced modules that can be accessed anytime and anywhere by employees. Alternative delivery methods can also reduce the cost and time required for in-person trainings, while still ensuring that employees receive consistent and relevant information on the company's privacy program. References: IAPP CIPM Study Guide, page 90; ISO/IEC 27002:2013, section 7.2.2


質問 # 100
In a sample metric template, what does "target" mean?

  • A. The suggested volume of data to collect
  • B. The percentage of completion
  • C. The frequency at which the data is sampled
  • D. The threshold for a satisfactory rating

正解：A


質問 # 101
Which statement is FALSE regarding the use of technical security controls?

  • A. Technical security controls deployed for one jurisdiction often satisfy another jurisdiction.
  • B. Most privacy legislation lists the types of technical security controls that must be implemented.
  • C. A person with security knowledge should be involved with the deployment of technical security controls.
  • D. Technical security controls are part of a data governance strategy.

正解：B

解説：
The statement that is false regarding the use of technical security controls is that most privacy legislation lists the types of technical security controls that must be implemented. Technical security controls are the hardware and software components that protect a system against cyberattacks, such as encryption, firewalls, antivirus software, and access control mechanisms1 However, most privacy legislation does not prescribe specific types of technical security controls that must be implemented by organizations. Instead, they usually require organizations to implement reasonable or appropriate technical security measures to protect personal data from unauthorized or unlawful access, use, disclosure, alteration, or destruction23 The exact level and type of technical security controls may depend on various factors, such as the nature and sensitivity of the data, the risks and threats involved, the state of the art technology available, and the cost and feasibility of implementation4 Therefore, organizations have some flexibility and discretion in choosing the most suitable technical security controls for their data processing activities. References: 1: Technical Controls - Cybersecurity Resilience - Resilient Energy Platform; 2: [General Data Protection Regulation (GDPR) - Official Legal Text], Article 32; 3: [Privacy Act 1988], Schedule 1 - Australian Privacy Principles (APPs), APP 11; 4: Technical Security Controls: Encryption, Firewalls & More


質問 # 102
SCENARIO
Please use the following to answer the next QUESTION:
Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.
Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal data. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.
Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following day, to get insight into how the office computer system is currently set-up and managed.
Richard needs to closely monitor the vendor in charge of creating the firm's database mainly because of what?

  • A. The vendor may not be aware of the privacy implications involved in the project.
  • B. The vendor will be in direct contact with all of the law firm's personal data.
  • C. The vendor will be required to report any privacy violations to the appropriate authorities.
  • D. The vendor may not be forthcoming about the vulnerabilities of the database.

正解：B

解説：
The main reason why Richard needs to closely monitor the vendor in charge of creating the firm's database is that the vendor will be in direct contact with all of the law firm's personal data. This means that the vendor will have access to sensitive and confidential information about the law firm's clients, such as their financial and medical data, which could expose them to identity theft, fraud, or other harms if mishandled or breached.
Therefore, Richard needs to ensure that the vendor follows the best practices of data protection and security, such as:
* Signing a data processing agreement that specifies the scope, purpose, duration, and terms of the data processing activities, as well as the rights and obligations of both parties.
* Implementing appropriate technical and organizational measures to protect the data from unauthorized or unlawful access, use, disclosure, alteration, or destruction, such as encryption, access control, backup and recovery, logging and monitoring, etc.
* Complying with the relevant laws and regulations that govern the collection, use, transfer, and retention of personal data, such as the GDPR or other local privacy laws.
* Reporting any data breaches or incidents to the law firm and the relevant authorities as soon as possible and taking corrective actions to mitigate the impact and prevent recurrence.
* Deleting or returning the data to the law firm after the completion of the project or upon request.


質問 # 103
SCENARIO
Please use the following to answer the next QUESTION:
It's just what you were afraid of. Without consulting you, the information technology director at your organization launched a new initiative to encourage employees to use personal devices for conducting business. The initiative made purchasing a new, high-specification laptop computer an attractive option, with discounted laptops paid for as a payroll deduction spread over a year of paychecks. The organization is also paying the sales taxes. It's a great deal, and after a month, more than half the organization's employees have signed on and acquired new laptops. Walking through the facility, you see them happily customizing and comparing notes on their new computers, and at the end of the day, most take their laptops with them, potentially carrying personal data to their homes or other unknown locations. It's enough to give you data- protection nightmares, and you've pointed out to the information technology Director and many others in the organization the potential hazards of this new practice, including the inevitability of eventual data loss or theft.
Today you have in your office a representative of the organization's marketing department who shares with you, reluctantly, a story with potentially serious consequences. The night before, straight from work, with laptop in hand, he went to the Bull and Horn Pub to play billiards with his friends. A fine night of sport and socializing began, with the laptop "safely" tucked on a bench, beneath his jacket. Later that night, when it was time to depart, he retrieved the jacket, but the laptop was gone. It was not beneath the bench or on another bench nearby. The waitstaff had not seen it. His friends were not playing a joke on him. After a sleepless night, he confirmed it this morning, stopping by the pub to talk to the cleanup crew. They had not found it.
The laptop was missing. Stolen, it seems. He looks at you, embarrassed and upset.
You ask him if the laptop contains any personal data from clients, and, sadly, he nods his head, yes. He believes it contains files on about 100 clients, including names, addresses and governmental identification numbers. He sighs and places his head in his hands in despair.
Which is the best way to ensure that data on personal equipment is protected?

  • A. Encryption of the data.
  • B. User risk training.
  • C. Biometric security.
  • D. Frequent data backups.

正解：A

解説：
Encryption of the data is the best way to ensure that data on personal equipment is protected, as it prevents unauthorized access to the data even if the equipment is lost or stolen. Encryption is the process of transforming data into an unreadable format that can only be decrypted with a valid key or password.
Encryption can be applied to the entire device, a specific folder or file, or a removable storage media. Encryption is one of the most effective technical safeguards for data protection and is recommended by many privacy laws and standards. References: IAPP CIPM Study Guide, page 831; ISO/IEC 27002:2013, section 10.1.1


質問 # 104
Which term describes a piece of personal data that alone may not identify an individual?

  • A. A single attribute
  • B. Unbundled data
  • C. Non-aggregated infopoint
  • D. A singularity

正解：A

解説：
A single attribute is a term that describes a piece of personal data that alone may not identify an individual, such as a first name or a zip code. However, when combined with other attributes, it may become identifiable. Reference: IAPP CIPM Study Guide, page 18.


質問 # 105
An organization is establishing a mission statement for its privacy program. Which of the following statements would be the best to use?

  • A. 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.
  • B. 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.
  • C. This privacy program encourages cross-organizational collaboration which will stop all data breaches
  • D. 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.

正解：B


質問 # 106
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.
Based on the scenario, Nationwide Grill needs to create better employee awareness of the company's privacy program by doing what?

  • A. Communicating to the staff more often.
  • B. Varying the modes of communication.
  • C. Improving inter-departmental cooperation.
  • D. Requiring acknowledgment of company memos.

正解：B

解説：
This answer is the best way to create better employee awareness of the company's privacy program, as it can increase the effectiveness and retention of the information by appealing to different learning styles and preferences. Varying the modes of communication can include using different formats and channels, such as posters, emails, memos, videos, webinars, podcasts, newsletters, quizzes, games or interactive modules.
Varying the modes of communication can also help to avoid information overload or duplication, which may cause employees to ignore or disregard the privacy messages. References: IAPP CIPM Study Guide, page 90; ISO/IEC 27002:2013, section 7.2.2


質問 # 107
What are you doing if you succumb to "overgeneralization" when analyzing data from metrics?

  • A. Possessing too many types of data to perform a valid analysis
  • B. Using limited data in an attempt to support broad conclusions
  • C. Trying to use several measurements to gauge one aspect of a program
  • D. Using data that is too broad to capture specific meanings

正解：D


質問 # 108
Which of the following is NOT an important factor to consider when developing a data retention policy?

  • A. Compliance requirement
  • B. Technology resource.
  • C. Organizational culture.
  • D. Business requirement.

正解：C

解説：
Organizational culture is not an important factor to consider when developing a data retention policy. A data retention policy is a document that defines how long an organization retains personal information for various purposes and how it disposes of it securely when it is no longer needed. A data retention policy should be based on factors such as: business requirements, such as operational needs, customer expectations, contractual obligations, or industry standards; compliance requirements, such as legal obligations, regulatory mandates, or audit recommendations; and technology resources, such as storage capacity, backup systems, encryption methods, or disposal tools. Organizational culture, which refers to the values, beliefs, norms, and behaviors that shape how an organization operates and interacts with its stakeholders, is not a relevant factor for determining data retention periods or disposal methods.
References:
CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B:
Protecting Personal Information, Subsection 4: Data Retention
CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.4: Data Retention CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.4: Data Retention CIPM Practice Exam (2021), Question 141


質問 # 109
Which term describes a piece of personal data that alone may not identify an individual?

  • A. A single attribute
  • B. Unbundled data
  • C. Non-aggregated infopoint
  • D. A singularity

正解：A

解説：
A single attribute is a term that describes a piece of personal data that alone may not identify an individual, such as a first name or a zip code. However, when combined with other attributes, it may become identifiable. References: IAPP CIPM Study Guide, page 18.


質問 # 110
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!" Which is the best first step in understanding the data security practices of a potential vendor?

  • A. Requiring the vendor to complete a questionnaire assessing International Organization for Standardization (ISO) 27001 compliance.
  • B. Examining investigation records of any breaches the vendor has experienced.
  • C. Conducting a physical audit of the vendor's facilities.
  • D. Conducting a penetration test of the vendor's data security structure.

正解：B


質問 # 111
Which of the following best demonstrates the effectiveness of a firm's privacy incident response process?

  • A. The decrease of mean time to resolve privacy incidents
  • B. The decrease of notifiable breaches
  • C. The decrease of security breaches
  • D. The increase of privacy incidents reported by users

正解：A

解説：
Explanation
The decrease of mean time to resolve privacy incidents best demonstrates the effectiveness of a firm's privacy incident response process. This metric measures how quickly and efficiently the firm can identify, contain, analyze, remediate, and report privacy incidents. A lower mean time to resolve indicates a higher level of preparedness, responsiveness, and resilience in handling privacy incidents. References: IAPP CIPM Study Guide, page 25.


質問 # 112
(The following are examples of privacy by design EXCEPT?)

  • A. Integrating pre-defined privacy controls into standard product launch procedures.
  • B. Conducting a root cause analysis on privacy incidents to recommend response improvements.
  • C. Assessing privacy risks in the architecture of a proposed customer-facing tool.
  • D. Incorporating privacy consultations into technology procurement requests.

正解：B

解説：
Privacy by design, as defined in CIPM, focuses on proactively embedding privacy controls into systems, processes, and technologies from the outset. Options A, B, and C all demonstrate forward-looking integration of privacy considerations during planning, design, and deployment phases.
Conducting a root cause analysis after a privacy incident is a reactive activity and falls under incident response and program improvement, not privacy by design. While such analysis is critical for maturity and prevention of future incidents, it does not represent designing privacy into systems before issues arise. CIPM clearly distinguishes between preventive design measures and corrective response actions, placing root cause analysis firmly in the latter category.


質問 # 113
......

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