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IAPP Certified Information Privacy Manager (CIPM) Sample Questions (Q161-Q166):

NEW QUESTION # 161
Which of the following best describes proper compliance for an international organization using Binding Corporate Rules (BCRs) as a controller or processor?

  • A. Employees who control personal data must complete a rigorous certification procedure, as they are exempt from legal enforcement.
  • B. All employees are subject to the rules in their entirety, regardless of where the work is taking place.
  • C. All employees must follow the privacy regulations of the jurisdictions where the current scope of their work is established.
  • D. Employees must sign an ad hoc contractual agreement each time personal data is exported.

Answer: C

Explanation:
Binding Corporate Rules (BCRs) are a mechanism for international organizations to transfer personal data within their group of companies across different jurisdictions, in compliance with the EU General Data Protection Regulation (GDPR) and other privacy laws. BCRs are legally binding and enforceable by data protection authorities and data subjects. BCRs must ensure that all employees who process personal data follow the privacy regulations of the jurisdictions where the data originates from, regardless of where they are located or where the data is transferred to. Reference: [Binding Corporate Rules], [BCRs for controllers], [BCRs for processors]


NEW QUESTION # 162
A minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) would include?

  • A. Assessment of security measures.
  • B. Monitoring of a publicly accessible area on a large scale.
  • C. Processing on a large scale of special categories of data.
  • D. Assessment of the necessity and proportionality.

Answer: C


NEW QUESTION # 163
SCENARIO
Please use the following to answer the next QUESTION:
As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically questionable practices, including unauthorized sales of personal data to marketers.
Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that
"appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.
Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures.
He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.
You are charged with making sure that privacy safeguards are in place for new products and initiatives. What is the best way to do this?

  • A. Institute Privacy by Design principles and practices across the organization
  • B. Hold a meeting with stakeholders to create an interdepartmental protocol for new initiatives
  • C. Develop a plan for introducing privacy protections into the product development stage
  • D. Conduct a gap analysis after deployment of new products, then mend any gaps that are revealed

Answer: A

Explanation:
Privacy by Design principles ensure that privacy considerations are integrated from the very beginning and throughout the entire product or initiative development process. This proactive approach not only ensures that privacy safeguards are in place from the start but can also be more cost-effective in the long run as it helps prevent potential breaches or issues that might arise later, saving on potential fines, reputational damage, and corrective actions.


NEW QUESTION # 164
In which situation would a Privacy Impact Assessment (PIA) be the least likely to be required?

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

Answer: A

Explanation:
Explanation
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). References: CIPM Study Guide, page 30; Guide to undertaking privacy impact assessments.


NEW QUESTION # 165
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!" You see evidence that company employees routinely circumvent the privacy officer in developing new initiatives.
How can you best draw attention to the scope of this problem?

  • A. Insist upon one-on-one consultation with each person who works around the privacy officer.
  • B. Develop a metric showing the number of initiatives launched without consultation and include it in reports, presentations, and consultation.
  • C. Take your concerns straight to the Chief Executive Officer.
  • D. Hold discussions with the department head of anyone who fails to consult with the privacy officer.

Answer: D


NEW QUESTION # 166
......

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