[2023] Use Valid New CIPM Test Notes & CIPM Valid Exam Guide
CIPM Actual Questions Answers PDF 100% Cover Real Exam Questions
IAPP CIPM (Certified Information Privacy Manager) certification exam is a globally recognized credential that demonstrates an individual's knowledge and expertise in managing privacy programs. Certified Information Privacy Manager (CIPM) certification exam is designed to test an individual's ability to manage, design, and implement privacy policies, procedures, and controls for organizations. The CIPM certification is ideal for those who wish to enhance their privacy management skills and gain recognition as a privacy professional.
The CIPM exam covers a broad range of topics related to privacy management, including privacy program governance, privacy program operationalization, privacy program assessment, and privacy program communication. CIPM exam also covers the legal and regulatory frameworks related to privacy, such as GDPR, CCPA, and HIPAA. The CIPM exam is designed for professionals with at least two years of experience in privacy management or a related field. CIPM exam consists of 90 multiple-choice questions and must be completed within two hours.
NEW QUESTION # 10
Which of the following is NOT a main technical data control area?
- A. Access controls.
- B. Data minimization.
- C. Obfuscation.
- D. Tokenization.
Answer: C
Explanation:
Explanation
Obfuscation is not a main technical data control area. Obfuscation means hiding or disguising data or information to make it less intelligible or accessible. Obfuscation can be used as a security measure or a privacy-enhancing technique, but it is not a specific type of data control. The main technical data control areas are tokenization, encryption, access controls, and data minimization. Tokenization means replacing sensitive data with non-sensitive substitutes called tokens that have no intrinsic value. Encryption means transforming data into an unreadable format that can only be decrypted with a key. Access controls mean restricting who can access or modify data based on their roles, permissions, or authentication methods. Data minimization means collecting, storing, and processing only the minimum amount of data necessary for a specific purpose1, 2. References: CIPM - International Association of Privacy Professionals, Free CIPM Study Guide - International Association of Privacy Professionals
NEW QUESTION # 11
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!" What safeguard can most efficiently ensure that privacy protection is a dimension of relationships with vendors?
- A. Do business only with vendors who are members of privacy trade associations
- B. Require that a person trained in privacy protection be part of all vendor selection teams
- C. Include appropriate language about privacy protection in vendor contracts
- D. Perform a privacy audit on any vendor under consideration
Answer: B
NEW QUESTION # 12
SCENARIO
Please use the following to answer the next QUESTION:
Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so anxious. Last week, a data processing firm used by the company reported that its system may have been hacked, and customer data such as names, addresses, and birthdays may have been compromised. Although the attempt was proven unsuccessful, the scare has prompted several Nationwide Grill executives to Question the company's privacy program at today's meeting.
Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to assure her that even if there had been an actual breach, the chances of a successful suit against the company were slim. But Alice remained unconvinced.
Spencer - a former CEO and currently a senior advisor - said that he had always warned against the use of contractors for data processing. At the very least, he argued, they should be held contractually liable for telling customers about any security incidents. In his view, Nationwide Grill should not be forced to soil the company name for a problem it did not cause.
One of the business development (BD) executives, Haley, then spoke, imploring everyone to see reason.
"Breaches can happen, despite organizations' best efforts," she remarked. "Reasonable preparedness is key." She reminded everyone of the incident seven years ago when the large grocery chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate culture, built up through many years of cultivating relationships, Haley was able to successfully manage the company's incident response.
Spencer replied that acting with reason means allowing security to be handled by the security functions within the company - not BD staff. In a similar way, he said, Human Resources (HR) needs to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill employees are overwhelmed with posters, emails, and memos from both HR and the ethics department related to the company's privacy program. Both the volume and the duplication of information means that it is often ignored altogether.
Spencer said, "The company needs to dedicate itself to its privacy program and set regular in-person trainings for all staff once a month." Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.
How could the objection to Spencer's training suggestion be addressed?
- A. By requiring training only on an as-needed basis.
- B. By customizing training based on length of employee tenure.
- C. By introducing a system of periodic refresher trainings.
- D. By offering alternative delivery methods for trainings.
Answer: D
NEW QUESTION # 13
Under which circumstances would people who work in human resources be considered a secondary audience for privacy metrics?
- A. They do not receive training on privacy issues
- B. They do not interface with the financial office
- C. They do not have frequent interactions with the public
- D. They do not have privacy policy as their main task
Answer: D
NEW QUESTION # 14
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 must Pacific Suite's primary focus be as it manages this security breach?
- A. Investigating the cause and assigning responsibility
- B. Determining whether the affected individuals should be notified
- C. Minimizing the amount of harm to the affected individuals
- D. Maintaining operations and preventing publicity
Answer: C
NEW QUESTION # 15
How are individual program needs and specific organizational goals identified in privacy framework development?
- A. By employing an industry-standard needs analysis.
- B. Through creation of the business case.
- C. By employing metrics to align privacy protection with objectives.
- D. Through conversations with the privacy team.
Answer: B
Explanation:
Explanation
The creation of the business case is the first step in privacy framework development, as it helps to identify the individual program needs and specific organizational goals. The business case is a document that outlines the rationale, objectives, benefits, costs, risks, and alternatives for implementing a privacy program. It also helps to communicate the value of privacy to stakeholders and gain their support. The other options are subsequent steps in privacy framework development, after the business case has been established. References: CIPM Study Guide, page 15.
NEW QUESTION # 16
Under the General Data Protection Regulation (GDPR), which situation would be LEAST likely to require a Data Protection Impact Assessment (DPIA)?
- A. A health clinic processing its patients' genetic and health data
- B. The use of a camera system to monitor driving behavior on highways
- C. An online magazine using a mailing list to send a generic daily digest to marketing emails
- D. A Human Resources department using a tool to monitor its employees' internet activity
Answer: C
NEW QUESTION # 17
Your company wants to convert paper records that contain customer personal information into electronic form, upload the records into a new third-party marketing tool and then merge the customer personal information in the marketing tool with information from other applications.
As the Privacy Officer, which of the following should you complete to effectively make these changes?
- A. A Personal Data Inventory.
- B. A Privacy Threshold Analysis (PTA).
- C. A Privacy Impact Assessment (PIA).
- D. A Record of Authority.
Answer: C
Explanation:
Explanation
A Privacy Impact Assessment (PIA) is a process that helps an organization identify and evaluate the potential privacy risks and impacts of a new or existing project, program, system, or service that involves the collection, use, disclosure, or retention of personal information. A PIA also helps an organization identify and implement appropriate measures to mitigate or eliminate those risks and impacts, and ensure compliance with applicable privacy laws, regulations, and standards. A PIA should be completed to effectively make changes that involve customer personal information, such as converting paper records into electronic form, uploading the records into a new third-party marketing tool, and merging the customer personal information in the marketing tool with information from other applications. A PIA can help an organization assess the necessity, proportionality, and legality of the proposed changes, as well as the potential privacy risks to the customers and the organization, such as unauthorized access, disclosure, modification, or loss of personal information, identity theft, fraud, reputational damage, or legal liability. A PIA can also help an organization implement appropriate measures to mitigate or eliminate those risks, such as data minimization, encryption, anonymization, pseudonymization, consent management, access control, security safeguards, contractual clauses, data protection impact assessments (DPIAs), data subject rights, breach notification procedures, and privacy policies.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section C:
Monitoring and Managing Program Performance Subsection 1: Privacy Impact Assessments1
* CIPM Study Guide (2021), Chapter 9: Monitoring and Managing Program Performance Section 9.1:
Privacy Impact Assessments2
* CIPM Textbook (2019), Chapter 9: Monitoring and Managing Program Performance Section 9.1:
Privacy Impact Assessments3
* CIPM Practice Exam (2021), Question 1464
NEW QUESTION # 18
Which of the following information must be provided by the data controller when complying with GDPR "right to be informed" requirements?
- A. The data subject's right to withdraw consent
- B. The contact details of the Data Protection Officer (DPO).
- C. The name of any organizations with whom personal data was shared.
- D. The purpose of personal data processing.
Answer: B
NEW QUESTION # 19
SCENARIO
Please use the following to answer the next question:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new privacy officer. The company is based in California but thanks to some great publicity from a social media influencer last year, the company has received an influx of sales from the EU and has set up a regional office in Ireland to support this expansion. To become familiar with Ace Space's practices and assess what her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the work that they have been doing and their compliance efforts.
Penny's colleague in Marketing is excited by the new sales and the company's plans, but is also concerned that Penny may curtail some of the growth opportunities he has planned. He tells her "I heard someone in the breakroom talking about some new privacy laws but I really don't think it affects us. We're just a small company. I mean we just sell accessories online, so what's the real risk?" He has also told her that he works with a number of small companies that help him get projects completed in a hurry. "We've got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that we just don't have." In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a number of precautions to protect its website from malicious activity, it has not taken the same level of care of its physical files or internal infrastructure. Penny's colleague in IT has told her that a former employee lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team
"didn't know what to do or who should do what. We hadn't been trained on it but we're a small team though, so it worked out OK in the end." Penny is concerned that these issues will compromise Ace Space's privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO to give the organization a data "shake up". Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space's CEO today and has been asked to give her first impressions and an overview of her next steps.
To establish the current baseline of Ace Space's privacy maturity, Penny should consider all of the following factors EXCEPT?
- A. Ace Space's employee training program
- B. Ace Space's vendor engagement protocols
- C. Ace Space's content sharing practices on social media
- D. Ace Space's documented procedures
Answer: D
NEW QUESTION # 20
SCENARIO
Please use the following to answer the next QUESTION:
Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.
The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.
Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.
In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the product. This data is all stored in the cloud and is encrypted both during transmission and at rest.
Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eurek a. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.
What administrative safeguards should be implemented to protect the collected data while in use by Manasa and her product management team?
- A. Conduct a Privacy Impact Assessment (PIA) to evaluate the risks involved.
- B. Implement a policy restricting data access on a "need to know" basis.
- C. Document the data flows for the collected data.
- D. Limit data transfers to the US by keeping data collected in Europe within a local data center.
Answer: C
NEW QUESTION # 21
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. Hold discussions with the department head of anyone who fails to consult with the privacy officer.
- C. Take your concerns straight to the Chief Executive Officer.
- D. Develop a metric showing the number of initiatives launched without consultation and include it in reports, presentations, and consultation.
Answer: D
Explanation:
Explanation
This answer is the best way to draw attention to the scope of this problem, as it can provide quantitative and objective evidence of how often the privacy officer is bypassed or ignored in the organization's data processing activities. Developing a metric showing the number of initiatives launched without consultation can help to measure and monitor the level of compliance and alignment with the organization's privacy program and policies, as well as the applicable laws and regulations. Including this metric in reports, presentations and consultation can help to communicate and raise awareness of this problem among the relevant stakeholders, such as senior management, project managers, developers or vendors. It can also help to demonstrate the value and importance of involving the privacy officer in the early stages of any initiative that involves personal data, as well as the potential consequences and risks of not doing so. References: IAPP CIPM Study Guide, page
891; ISO/IEC 27002:2013, section 18.1.3
NEW QUESTION # 22
SCENARIO
Please use the following to answer the next question:
For 15 years, Albert has worked at Treasure Box - a mail order company in the United States (U.S.) that used to sell decorative candles around the world, but has recently decided to limit its shipments to customers in the
48 contiguous states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not being promoted, coupled with his recent interest in issues of privacy protection, have motivated Albert to be an agent of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives aware of lapses in the company's privacy program. He feels certain he will be rewarded with a promotion for preventing negative consequences resulting from the company's outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful way to measure Treasure Box's ability to protect personal data. Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company's commitment to the security of customer and employee personal data against external threats. However, Albert worries about the high turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two recent security incidents. The company has responded to the incidents with internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help the company recover.
He knows there is at least one incident the public in unaware of, although Albert does not know the details. He believes the company's insistence on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company's recent business maneuvers will also impress the interviewers. For example, Albert is aware of the company's intention to acquire a medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.
On which of the following topics does Albert most likely need additional knowledge?
- A. The necessary maturity level of privacy programs
- B. The possibility of delegating responsibilities related to privacy
- C. The requirements for a managerial position with privacy protection duties
- D. The role of privacy in retail companies
Answer: B
NEW QUESTION # 23
Under the General Data Protection Regulation (GDPR), which of the following situations would LEAST likely require a controller to notify a data subject?
- A. An encrypted USB key with sensitive personal data is stolen
- B. Personal data of a group of individuals is erroneously sent to the wrong mailing list
- C. A direct marketing email is sent with recipients visible in the 'cc' field
- D. A hacker publishes usernames, phone numbers and purchase history online after a cyber-attack
Answer: C
NEW QUESTION # 24
Which of the following is NOT an important factor to consider when developing a data retention policy?
- A. Technology resource.
- B. Business requirement.
- C. Compliance requirement
- D. Organizational culture.
Answer: A
NEW QUESTION # 25
What is the name for the privacy strategy model that describes delegated decision making?
- A. De-functionalized.
- B. Hybrid.
- C. Matrix.
- D. De-centralized.
Answer: D
NEW QUESTION # 26
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.
How was Pacific Suites responsible for protecting the sensitive information of its offshoot, PHT?
- A. As the parent company, it should have transferred personnel to oversee the secure handling of PHT's data.
- B. As the parent company, it should have performed an assessment of PHT's infrastructure and confirmed complete separation of the two networks.
- C. As the parent company, it should have replaced PHT's electronic files with hard-copy documents stored securely on site.
- D. As the parent company, it should have ensured its existing data access and storage procedures were integrated into PHT's system.
Answer: D
NEW QUESTION # 27
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 Lifecycle 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
This series of standards provides a framework for establishing, implementing, maintaining and improving an information security management system (ISMS), which includes data protection as a key component.
NEW QUESTION # 28
There are different forms of monitoring available for organizations to consider when aligning with their privacy program goals.
Which of the following forms of monitoring is best described as 'auditing'?
- A. Ensuring third parties have appropriate security and privacy requirements in place.
- B. Assisting in the completion of attesting reporting for SOC2, ISO, or BS7799.
- C. Evaluating operations, systems, and processes.
- D. Tracking, reporting and documenting complaints from all sources.
Answer: C
NEW QUESTION # 29
SCENARIO
Please use the following to answer the next QUESTION:
For 15 years, Albert has worked at Treasure Box - a mail order company in the United States (U.S.) that used to sell decorative candles around the world, but has recently decided to limit its shipments to customers in the 48 contiguous states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not being promoted, coupled with his recent interest in issues of privacy protection, have motivated Albert to be an agent of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives aware of lapses in the company's privacy program. He feels certain he will be rewarded with a promotion for preventing negative consequences resulting from the company's outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful way to measure Treasure Box's ability to protect personal dat a. Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company's commitment to the security of customer and employee personal data against external threats. However, Albert worries about the high turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two recent security incidents. The company has responded to the incidents with internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help the company recover. He knows there is at least one incident the public in unaware of, although Albert does not know the details. He believes the company's insistence on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company's recent business maneuvers will also impress the interviewers. For example, Albert is aware of the company's intention to acquire a medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the job.
Based on Albert's observations regarding recent security incidents, which of the following should he suggest as a priority for Treasure Box?
- A. Appointing an internal ombudsman to address employee complaints regarding hours and pay.
- B. Working with the Human Resources department to make screening procedures for potential employees more rigorous.
- C. Using a third-party auditor to address privacy protection issues not recognized by the prior internal audits.
- D. Evaluating the company's ability to handle personal health information if the plan to acquire the medical supply company goes forward
Answer: D
NEW QUESTION # 30
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 Lifecycle Management Standards.
- B. International Organization for Standardization 27000 Series.
- C. United Nations Privacy Agency Standards.
- D. International Organization for Standardization 9000 Series.
Answer: B
NEW QUESTION # 31
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 process can best answer your Questions about the vendor's data security safeguards?
- A. A public records search for earlier legal violations
- B. A second-party of supplier audit
- C. A table top demonstration of a potential threat
- D. A reference check with other clients
Answer: B
Explanation:
Explanation
This answer is the best process to answer Albert's questions about the vendor's data security safeguards, as it can provide a direct and comprehensive way to assess and verify the vendor's compliance with the applicable laws, regulations, standards and best practices for data protection. A second-party or supplier audit is conducted by the organization that hires or contracts the vendor to evaluate their performance and alignment with the organization's standards and expectations. A second-party or supplier audit can also help to identify any gaps, weaknesses or risks in the vendor's data security safeguards, and to recommend or require any improvements or corrective actions.
NEW QUESTION # 32
How do privacy audits differ from privacy assessments?
- A. They are based on standards.
- B. They are non-binding.
- C. They are evidence-based.
- D. They are conducted by external parties.
Answer: A
NEW QUESTION # 33
Why were the nongovernmental privacy organizations, Electronic Frontier Foundation (EFF) and Electronic Privacy Information Center (EPIC), established?
- A. To promote security on the Internet through strong encryption
- B. To protect civil liberties and raise consumer awareness
- C. To promote consumer confidence in the Internet industry
- D. To improve the user experience during online shopping
Answer: B
NEW QUESTION # 34
A Human Resources director at a company reported that a laptop containing employee payroll data was lost on the train. Which action should the company take IMMEDIATELY?
- A. Perform a multi-factor risk analysis
- B. Report the theft to the senior management
- C. Wipe the hard drive remotely
- D. Report the theft to law enforcement
Answer: A
Explanation:
Explanation
The company should perform a multi-factor risk analysis immediately after discovering the loss of the laptop containing employee payroll data. A multi-factor risk analysis is a process of assessing the potential impact and likelihood of a data breach, taking into account various factors such as the nature, scope, context, and purpose of the processing, the type and severity of the harm that may result from the breach, the number and categories of data subjects and personal data affected, the measures taken to mitigate the risk, and any relevant legal obligations or codes of conduct. A multi-factor risk analysis can help the company determine whether the breach poses a high risk to the rights and freedoms of the data subjects, and whether it needs to notify them and/or the relevant supervisory authority without undue delay, as required by Article 33 and 34 of the GDPR1.
A multi-factor risk analysis can also help the company identify the root cause of the breach, evaluate the effectiveness of its existing security measures, and implement appropriate corrective actions to prevent or minimize similar incidents in the future.
References:
* CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section B:
Protecting Personal Information, Subsection 2: Data Breach Incident Planning and Management2
* CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management3
* CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident Planning and Management4
* CIPM Practice Exam (2021), Question 1285
* GDPR Article 33 and 341
NEW QUESTION # 35
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The CIPM exam consists of 90 multiple-choice questions and must be completed within three hours. The passing score is 300 out of a possible 500 points. CIPM exam is administered at Pearson VUE testing centers around the world.
CIPM Exam questions and answers: https://actualtests.real4prep.com/CIPM-exam.html