What CDPSE Questions and Answers feature?

Before using data from the organization’s customer database for a new marketing application, the first step should be to determine what data is required by the application and for what purpose. This will help to ensure that the data collection and processing are relevant, necessary, and proportionate to the intended use, and that the data minimization principle is followed. Data minimization means that only the minimum amount of personal data needed to achieve a specific purpose should be collected and processed, and that any excess or irrelevant data should be deleted or anonymized1. This will also help to comply with the data privacy laws and regulations that apply to the organization, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which require organizations to inform data subjects about the types and purposes of data processing, and to obtain their consent if needed23.

Input validation controls are the best way to ensure consumer credit card numbers are accurately captured. Input validation controls are methods that check the format, type, range, and length of the input data before accepting, processing, or storing it. Input validation controls can help prevent errors, fraud, or data loss by rejecting invalid, incomplete, or malicious input. For example, input validation controls can verify that a credit card number follows the Luhn algorithm1, has the correct number of digits2, and matches the card issuer’s prefix3. Input validation controls can also prevent SQL injection attacks4 or cross-site scripting attacks5 that may compromise the security and privacy of the data.

Input reference controls, access controls, and reconciliation controls are also important for data quality and security, but they do not directly ensure the accuracy of consumer credit card numbers. Input reference controls are methods that compare the input data with a predefined list of values or a reference table to ensure consistency and validity. For example, input reference controls can check if a country name or a postal code is valid by looking up a database of valid values. Access controls are methods that restrict who can access, modify, or delete the data based on their roles, permissions, or credentials. For example, access controls can prevent unauthorized users from accessing or tampering with consumer credit card numbers. Reconciliation controls are methods that compare the data from different sources or systems to ensure completeness and accuracy. For example, reconciliation controls can check if the transactions recorded in the accounting system match the transactions processed by the payment gateway.

The best way for an organization to maintain the effectiveness of its privacy breach incident response plan is to conduct annual data privacy tabletop exercises. A data privacy tabletop exercise is a simulated scenario that tests the organization’s ability to respond to a privacy breach incident, such as a data breach, leak, or misuse. A data privacy tabletop exercise involves key stakeholders, such as the privacy office, the information security team, the legal counsel, the public relations team, etc., who role-play their actions and decisions based on the scenario. A data privacy tabletop exercise helps to evaluate and improve the organization’s privacy breach incident response plan, such as identifying gaps or weaknesses, validating roles and responsibilities, verifying procedures and protocols, assessing communication and coordination, etc. References: : CDPSE Review Manual (Digital Version), page 83