CDPSE Exam Dumps - Certified Data Privacy Solutions Engineer

Reviewing proposed privacy rules that govern the processing of personal data is the most useful action to help define the scope of the project because it helps identify the legal and regulatory requirements, the data protection principles and the privacy objectives that the information security controls need to support. Reviewing recent audit reports, identifying databases that contain personal data or do not have encryption in place are helpful actions to assess the current state of privacy and security, but they do not provide a clear direction for the project scope.

References:

• CDPSE Review Manual (Digital Version), Domain 2: Privacy Architecture, Task 2.1: Identify and/or define privacy requirements1
• CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 3: Privacy Architecture, Section: Privacy Requirements2

The first consideration when conducting a privacy impact assessment (PIA) is the applicable privacy legislation that governs the collection, processing, storage, transfer, and disposal of personal data within the scope of the assessment. The applicable privacy legislation may vary depending on the jurisdiction, sector, or purpose of the data processing activity. The PIA should identify and comply with the relevant legal requirements and obligations for data protection and privacy, such as obtaining consent, providing notice, ensuring data quality and security, respecting data subject rights, and reporting data breaches. The applicable privacy legislation also determines the criteria, methodology, and documentation for conducting the PIA.

References:

• ISACA, Performing an Information Security and Privacy Risk Assessment1
• ISACA, Best Practices for Privacy Audits2
• ISACA, GDPR Data Protection Impact Assessments3
• ISACA, GDPR Data Protection Impact Assessment Template4

Some organizations, typically those that manage large amounts of personal information related to employees, customers, or constituents, will employ a chief privacy officer (CPO). Some organizations have a CPO because applicable regulations such as the Gramm-Leach-Bliley Act (GLBA) require it. Other regulations such as the Health Information Portability and Accountability Act (HIPAA), the Fair Credit Reporting Act (FCRA), and the GLBA place a slate of responsibilities upon an organization that compels them to hire an executive responsible for overseeing compliance.

The chief privacy officer (CPO) is the senior executive who is responsible for establishing and maintaining the organization’s privacy vision, strategy, and program. The CPO oversees the development and implementation of privacy policies, procedures, standards, and controls, and ensures that they align with the organization’s business objectives and legal obligations. The CPO also leads the privacy governance structure, such as the privacy steering committee, and coordinates with other stakeholders, such as the chief data officer (CDO), the information security steering committee, and the legal counsel, to ensure that privacy is integrated into all aspects of the organization’s operations. References: : CDPSE Review Manual (Digital Version), page 21

Senior leadership must define the roles and responsibilities of the person with oversight, who is responsible for ensuring compliance with the data privacy policy and applicable laws and regulations. This person may also be known as the data protection officer, the privacy officer, or the chief privacy officer, depending on the organization and jurisdiction. The person with oversight should have the authority, resources, and independence to perform their duties effectively.

References:

• ISACA, CDPSE Review Manual 2021, Chapter 2: Privacy Governance, Section 2.1: Privacy Governance Framework, p. 35-36.
• ISACA, Data Privacy Audit/Assurance Program, Control Objective 1: Data Privacy Governance, p. 4-51

The best way to ensure an effective data privacy policy is implemented is to align regulatory requirements with business needs, because this will help achieve compliance while also supporting the organization’s objectives, values, and strategies. A data privacy policy should reflect the legal obligations and expectations of the organization, as well as the needs and preferences of its stakeholders, such as customers, employees, partners, and regulators. A data privacy policy should also be flexible and adaptable to changing circumstances and environments12.

References:

• CDPSE Exam Content Outline, Domain 1 – Privacy Governance (Governance, Management & Risk Management), Task 3: Participate in the evaluation of privacy policies, programs and policies for their alignment with legal requirements, regulatory requirements and/or industry best practices3.
• CDPSE Review Manual, Chapter 1 – Privacy Governance, Section 1.2 – Privacy Policy4.