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CIPM Exam Dumps - Certified Information Privacy Manager (CIPM)

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Question # 33

SCENARIO

Please use the following to answer the next QUESTION:

Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the company, Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year, news broke that a police sting operation had revealed a drug ring operating in the Providence, Rhode Island office in the United States. Video from the office's video surveillance cameras leaked to news operations showed a drug exchange between Special Handling staff and undercover officers.

In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that upper management believed had let the criminal elements conduct their illicit transactions. After a few weeks under Kelly's direction, the office became a model of efficiency and customer service. Kelly monitored his workers' activities using the same cameras that had recorded the illegal conduct of their former co-workers.

Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The company has received numerous reports of the staff leaving the office unattended. When Kelly arrived, he found that even when present, the staff often spent their days socializing or conducting personal business on their mobile phones. Again, he observed their behaviors using surveillance cameras. He issued written reprimands to six staff members based on the first day of video alone.

Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data Protection Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was told that the company's license for the cameras listed facility security as their main use, but he does not know why this matters. He has pointed out to his superiors that the company's training programs on privacy protection and data collection mention nothing about surveillance video.

You are a privacy protection consultant, hired by the company to assess this incident, report on the legal and compliance issues, and recommend next steps.

Knowing that the regulator is now investigating, what would be the best step to take?

A.

Consult an attorney experienced in privacy law and litigation.

B.

Use your background and knowledge to set a course of action.

C.

If you know the organization is guilty, advise it to accept the punishment.

D.

Negotiate the terms of a settlement before formal legal action takes place.

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Question # 34

Which of the following practices best ensures the continuous assessment of program performance within the operational life cycle?

A.

Completing third-party audits by subject matter experts.

B.

Prioritizing ongoing improvement efforts.

C.

Evaluating emerging risks every 24 months.

D.

Allocating training costs in favor of the privacy and security teams.

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Question # 35

What is the main reason to begin with 3-5 key metrics during the program development process?

A.

To avoid undue financial costs.

B.

To keep the focus on the main organizational objectives.

C.

To minimize selective data use.

D.

To keep the process limited to as few people as possible.

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Question # 36

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.

From a business standpoint, what is the most productive way to view employee use of personal equipment for work-related tasks?

A.

The use of personal equipment is a cost-effective measure that leads to no greater security risks than are always present in a modern organization.

B.

Any computer or other equipment is company property whenever it is used for company business.

C.

While the company may not own the equipment, it is required to protect the business-related data on any equipment used by its employees.

D.

The use of personal equipment must be reduced as it leads to inevitable security risks.

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Question # 37

A start-up tech company is developing its privacy policies and processes.

Which policy is most important to ensure the organization is successful at processing consumer health information?

A.

The employee notice.

B.

The consumer health data policy.

C.

The privacy impact assessment (PIA).

D.

The Health Insurance Portability and Accountability Act (HIPAA) privacy notice.

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Question # 38

SCENARIO

Please use the following to answer the next question:

Recently, a boutique fashion company headquartered in California, US needed to fill a very large online order from one of their best customers located in France. The boutique did not have all the items needed to complete the order, so they asked one of their partners located in Canada to help fulfill the order. To save time, the boutique had the items shipped directly from the Canadian partner’s store to the customer’s home address. The partner sent SMS messages to provide the customer with direct shipping updates.

The merchandise arrived to the customer and they were happy with the experience. However, soon after, the customer contacted the boutique to complain that they had been receiving telemarketing calls and emails from other fashion boutiques and stores.

What should the boutique have done to properly handle and govern the customer’s personal information?

A.

Performed a sub-processor due diligence review of the partner store.

B.

Ensured that standard contractual clauses were in place between the boutique and the partner store.

C.

Ensured that Canada has received an adequacy decision by European Commission before moving forward with the transaction.

D.

Notified the customer that part of their order would be fulfilled by the partner and obtain the customer’s opt-in consent before sharing any data.

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Question # 39

SCENARIO

Please use the following to answer the next QUESTION:

Your organization, the Chicago (U.S.)-based Society for Urban Greenspace, has used the same vendor to operate all aspects of an online store for several years. As a small nonprofit, the Society cannot afford the higher-priced options, but you have been relatively satisfied with this budget vendor, Shopping Cart Saver (SCS). Yes, there have been some issues. Twice, people who purchased items from the store have had their credit card information used fraudulently subsequent to transactions on your site, but in neither case did the investigation reveal with certainty that the Society’s store had been hacked. The thefts could have been employee-related.

Just as disconcerting was an incident where the organization discovered that SCS had sold information it had collected from customers to third parties. However, as Jason Roland, your SCS account representative, points out, it took only a phone call from you to clarify expectations and the “misunderstanding” has not occurred again.

As an information-technology program manager with the Society, the role of the privacy professional is only one of many you play. In all matters, however, you must consider the financial bottom line. While these problems with privacy protection have been significant, the additional revenues of sales of items such as shirts and coffee cups from the store have been significant. The Society’s operating budget is slim, and all sources of revenue are essential.

Now a new challenge has arisen. Jason called to say that starting in two weeks, the customer data from the store would now be stored on a data cloud. “The good news,” he says, “is that we have found a low-cost provider in Finland, where the data would also be held. So, while there may be a small charge to pass through to you, it won’t be exorbitant, especially considering the advantages of a cloud.”

Lately, you have been hearing about cloud computing and you know it’s fast becoming the new paradigm for various applications. However, you have heard mixed reviews about the potential impacts on privacy protection. You begin to research and discover that a number of the leading cloud service providers have signed a letter of intent to work together on shared conventions and technologies for privacy protection. You make a note to find out if Jason’s Finnish provider is signing on.

What is the best way to prevent the Finnish vendor from transferring data to another party?

A.

Restrict the vendor to using company security controls

B.

Offer company resources to assist with the processing

C.

Include transfer prohibitions in the vendor contract

D.

Lock the data down in its current location

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Question # 40

With whom would it be best for a privacy professional in an organization to consult regarding Privacy-Enhancing Technologies (PETs)?

A.

A specialist focused on AI.

B.

An independent privacy technology advocate.

C.

An engineer who designs information security technology products.

D.

An information technologist specializing in information privacy technology.

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