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IAPP Certified Information Privacy Manager (CIPM) Sample Questions (Q197-Q202):

NEW QUESTION # 197
Rationalizing requirements in order to comply with the various privacy requirements required by applicable law and regulation does NOT include which of the following?

A. Harmonizing shared obligations and privacy rights across varying legislation and/or regulators.
B. Applying the strictest standard for obligations and privacy rights that doesn't violate privacy laws elsewhere.
C. Addressing requirements that fall outside the common obligations and rights (outliers) on a case-by-case basis.
D. Implementing a solution that significantly addresses shared obligations and privacy rights.

Answer: B

Explanation:
Rationalizing requirements in order to comply with the various privacy requirements required by applicable law and regulation means that you have a systematic and logical approach to harmonize and streamline your compliance efforts. Rationalizing requirements does include harmonizing shared obligations and privacy rights across varying legislation and/or regulators, implementing a solution that significantly addresses shared obligations and privacy rights, and addressing requirements that fall outside the common obligations and rights (outliers) on a case-by-case basis. These steps can help you avoid duplication, inconsistency, or inefficiency in your compliance activities.

NEW QUESTION # 198
An organization is establishing a mission statement for its privacy program. Which of the following statements would be the best to use?

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

Answer: D

Explanation:
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. Reference: IAPP CIPM Study Guide, page 18.

NEW QUESTION # 199
SCENARIO
Please use the following to answer the next question:
As the director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.
You are left contemplating: What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success? What are the next action steps?
Which of the following would be most effectively used as a guide to a systems approach to implementing data protection?

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

Answer: B

Explanation:
Explanation/Reference: https://www.itgovernance.co.uk/blog/what-is-the-iso-27000-series-of-standards

NEW QUESTION # 200
SCENARIO
Please use the following to answer the next question:
Martin Briseno is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseno decided to change the hotel's on-the-job mentoring model to a standardized training program for employees who were progressing from line positions into supervisory positions. He developed a curriculum comprising a series of lessons, scenarios, and assessments, which was delivered in-person to small groups. Interest in the training increased, leading Briseno to work with corporate HR specialists and software engineers to offer the program in an online format. The online program saved the cost of a trainer and allowed participants to work through the material at their own pace.
Upon hearing about the success of Briseno's program, Pacific Suites corporate Vice President Maryanne Silva-Hayes expanded the training and offered it company-wide. Employees who completed the program received certification as a Pacific Suites Hospitality Supervisor. By 2001, the program had grown to provide industry-wide training. Personnel at hotels across the country could sign up and pay to take the course online.
As the program became increasingly profitable, Pacific Suites developed an offshoot business, Pacific Hospitality Training (PHT). The sole focus of PHT was developing and marketing a variety of online courses and course progressions providing a number of professional certifications in the hospitality industry.
By setting up a user account with PHT, course participants could access an information library, sign up for courses, and take end-of-course certification tests. When a user opened a new account, all information was saved by default, including the user's name, date of birth, contact information, credit card information, employer, and job title. The registration page offered an opt-out choice that users could click to not have their credit card numbers saved. Once a user name and password were established, users could return to check their course status, review and reprint their certifications, and sign up and pay for new courses. Between 2002 and
2008, PHT issued more than 700,000 professional certifications.
PHT's profits declined in 2009 and 2010, the victim of industry downsizing and increased competition from e- learning providers. By 2011, Pacific Suites was out of the online certification business and PHT was dissolved.
The training program's systems and records remained in Pacific Suites' digital archives, un-accessed and unused. Briseno and Silva-Hayes moved on to work for other companies, and there was no plan for handling the archived data after the program ended. After PHT was dissolved, Pacific Suites executives turned their attention to crucial day-to-day operations. They planned to deal with the PHT materials once resources allowed.
In 2012, the Pacific Suites computer network was hacked. Malware installed on the online reservation system exposed the credit card information of hundreds of hotel guests. While targeting the financial data on the reservation site, hackers also discovered the archived training course data and registration accounts of Pacific Hospitality Training's customers. The result of the hack was the exfiltration of the credit card numbers of recent hotel guests and the exfiltration of the PHT database with all its contents.
A Pacific Suites systems analyst discovered the information security breach in a routine scan of activity reports. Pacific Suites quickly notified credit card companies and recent hotel guests of the breach, attempting to prevent serious harm. Technical security engineers faced a challenge in dealing with the PHT data.
PHT course administrators and the IT engineers did not have a system for tracking, cataloguing, and storing information. Pacific Suites has procedures in place for data access and storage, but those procedures were not implemented when PHT was formed. When the PHT database was acquired by Pacific Suites, it had no owner or oversight. By the time technical security engineers determined what private information was compromised, at least 8,000 credit card holders were potential victims of fraudulent activity.
What key mistake set the company up to be vulnerable to a security breach?

A. Overlooking the need to organize and categorize data
B. Neglecting to make a backup copy of archived electronic files
C. Failing to outsource training and data management to professionals
D. Collecting too much information and keeping it for too long

Answer: A

NEW QUESTION # 201
Which of the following best supports implementing controls to bring privacy policies into effect?

A. The information technology (IT) group supporting and enhancing the privacy program and privacy policy by developing processes and controls.
B. The Chief Information Officer as part of the Senior Management Team creating enterprise privacy policies to ensure controls are available.
C. The legal department or outside counsel conducting a thorough review of the privacy program and policies.
D. The internal audit department establishing the audit controls which test for policy effectiveness.

Answer: A

Explanation:
The information technology (IT) group supporting and enhancing the privacy program and privacy policy by developing processes and controls best supports implementing controls to bring privacy policies into effect. Privacy policies are documents that define the organization's principles, commitments, and practices for collecting, using, disclosing, retaining, and protecting personal information. Privacy policies need to be translated into operational processes and controls that ensure compliance with the policy objectives and requirements. The IT group can support and enhance the privacy program and privacy policy by developing processes and controls such as: data classification, data inventory, data mapping, data minimization, consent management, access control, encryption, pseudonymization, anonymization, security safeguards, breach detection and response, data subject rights fulfillment, data retention and disposal, audit logging and monitoring, privacy by design and default, privacy impact assessments, privacy notices and statements, privacy training and awareness.
Reference:
CIPM Body of Knowledge (2021), Domain II: Privacy Program Framework, Section A: Privacy Program Framework Components Subsection 1: Privacy Policies CIPM Study Guide (2021), Chapter 4: Privacy Program Framework Components Section 4.1: Privacy Policies CIPM Textbook (2019), Chapter 4: Privacy Program Framework Components Section 4.1: Privacy Policies CIPM Practice Exam (2021), Question 148

NEW QUESTION # 202
......

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Neil Young Neil Young

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