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NEW QUESTION # 104
Which of the following poses the GREATEST privacy risk for client-side application processing?
- A. A distributed denial of service attack (DDoS) on the company network
- B. Failure of a firewall protecting the company network
- C. An employee loading personal information on a company laptop
- D. A remote employee placing communication software on a company server
Answer: D
NEW QUESTION # 105
A new marketing application needs to use data from the organization's customer database. Prior to the application using the data, which of the following should be done FIRST?
- A. Ensure the data loss prevention (DLP) tool is logging activity.
- B. Renew the encryption key to include the application.
- C. De-identify all personal data in the database.
- D. Determine what data is required by the application.
Answer: D
Explanation:
Explanation
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.
References:
ISACA, Data Privacy Audit/Assurance Program, Control Objective 2: Data Minimization, p. 61 ISACA, GDPR Data Protection Impact Assessments, p. 4-52 ISACA, CCPA vs. GDPR: Similarities and Differences, p. 1-23
NEW QUESTION # 106
Which of the following is the BEST indication of a highly effective privacy training program?
- A. HR has made privacy training an annual mandate for the organization_
- B. No privacy incidents have been reported in the last year
- C. Recent audits have no findings or recommendations related to data privacy
- D. Members of the workforce understand their roles in protecting data privacy
Answer: D
Explanation:
Explanation
The best indication of a highly effective privacy training program is that members of the workforce understand their roles in protecting data privacy, because this shows that the training program has successfully raised the awareness and knowledge of the workforce on the importance, principles and practices of data privacy, and how they can contribute to the organization's privacy objectives and compliance. According to ISACA, one of the key elements of a privacy training program is to define and communicate the roles and responsibilities of the workforce in relation to data privacy1. Members of the workforce who understand their roles in protecting data privacy are more likely to follow the privacy policies and procedures, report any privacy incidents or issues, and support the privacy culture of the organization2. Recent audits have no findings or recommendations related to data privacy, no privacy incidents have been reported in the last year, and HR has made privacy training an annual mandate for the organization are not as reliable as members of the workforce understand their roles in protecting data privacy, as they do not necessarily reflect the effectiveness of the privacy training program, but rather the performance of other factors such as audit processes, incident management systems, or HR policies.
NEW QUESTION # 107
Which of the following is MOST likely to present a valid use case for keeping a customer's personal data after contract termination?
- A. A forthcoming campaign to win back customers
- B. Ease of onboarding when the customer returns
- C. A required retention period due to regulations
- D. For the purpose of medical research
Answer: C
NEW QUESTION # 108
Which of the following is the BEST approach for a local office of a global organization faced with multiple privacy-related compliance requirements?
- A. Focus on global compliance before meeting local requirements.
- B. Focus on requirements with the highest organizational impact.
- C. Focus on local standards before meeting global compliance.
- D. Focus on developing a risk action plan based on audit reports.
Answer: B
Explanation:
Explanation
The best approach for a local office of a global organization faced with multiple privacy-related compliance requirements is to focus on the requirements with the highest organizational impact, because this will help prioritize the most critical and urgent privacy issues and risks that may affect the organization's reputation, operations, or legal obligations. Focusing on the highest impact requirements will also help allocate the resources and efforts more efficiently and effectively, as well as align the local office's privacy practices with the global organization's objectives and strategies12.
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.
NEW QUESTION # 109
A data processor that handles personal data tor multiple customers has decided to migrate its data warehouse to a third-party provider. What is the processor obligated to do prior to implementation?
- A. Obtain assurance that data subject requests will continue to be handled appropriately
- B. Implement comparable industry-standard data encryption in the new data warehouse
- C. Ensure data retention periods are documented
- D. Seek approval from all in-scope data controllers.
Answer: D
Explanation:
Explanation
A data processor that handles personal data for multiple customers has decided to migrate its data warehouse to a third-party provider. The processor is obligated to seek approval from all in-scope data controllers prior to implementation. A data controller is an entity that determines the purposes and means of processing personal data. A data processor is an entity that processes personal data on behalf of a data controller. A third-party provider is an entity that provides services or resources to another entity, such as a cloud service provider or a hosting provider.
According to various privacy laws and regulations, such as the GDPR or the CCPA, a data processor must obtain explicit consent from the data controller before engaging another processor or transferring personal data to a third country or an international organization. The consent must specify the identity of the other processor or the third country or international organization, as well as the safeguards and guarantees for the protection of personal data. The consent must also be documented in a written contract or other legal act that binds the processor to respect the same obligations as the controller.
Seeking approval from all in-scope data controllers can help ensure that the processor complies with its contractual and legal obligations, respects the rights and preferences of the data subjects, and maintains transparency and accountability for its processing activities.
Obtaining assurance that data subject requests will continue to be handled appropriately, implementing comparable industry-standard data encryption in the new data warehouse, or ensuring data retention periods are documented are also good practices for a data processor that migrates its data warehouse to a third-party provider, but they are not obligations prior to implementation. Rather, they are requirements or recommendations during or after implementation.
Obtaining assurance that data subject requests will continue to be handled appropriately is a requirement for a data processor that processes personal data on behalf of a data controller. Data subject requests are requests made by individuals to exercise their rights regarding their personal data, such as access, rectification, erasure, restriction, portability, or objection. A data processor must assist the data controller in fulfilling these requests within a reasonable time frame and without undue delay.
Implementing comparable industry-standard data encryption in the new data warehouse is a recommendation for a data processor that transfers personal data to another system or location. Data encryption is a process of transforming data into an unreadable form using a secret key or algorithm. Data encryption can help protect the confidentiality, integrity, and availability of personal data by preventing unauthorized access, disclosure, or modification.
Ensuring data retention periods are documented is a requirement for a data processor that stores personal data on behalf of a data controller. Data retention periods are the durations for which personal data are kept before they are deleted or anonymized. Data retention periods must be determined by the purpose and necessity of processing personal data and must comply with legal and regulatory obligations.
References: Data warehouse migration tips: preparation and discovery - Google Cloud, Plan a data warehouse migration - Cloud Adoption Framework, Migrating your traditional data warehouse platform to BigQuery ...
NEW QUESTION # 110
Which of the following is the BEST way to reduce the risk of compromise when transferring personal information using email?
- A. Password-protected .zip files
- B. End user-managed encryption
- C. Private cloud storage space
- D. Centrally managed encryption
Answer: D
Explanation:
Explanation
Encryption is a security practice that transforms data into an unreadable format using a secret key or algorithm. Encryption protects the confidentiality and integrity of data, especially when they are transferred using email or other communication channels. Encryption ensures that only authorized parties can access and use the data, while unauthorized parties cannot decipher or modify the data without the key or algorithm.
Encryption also helps to comply with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which require data controllers and processors to implement appropriate technical and organizational measures to safeguard personal data.
Centrally managed encryption is a type of encryption that is implemented and controlled by a central authority or system, such as an organization or a service provider. Centrally managed encryption has the following advantages over end user-managed encryption, private cloud storage space, or password-protected .zip files, for reducing the risk of compromise when transferring personal information using email:
* It can enforce consistent and standardized encryption policies and procedures across the organization or the service, such as the encryption standards, algorithms, keys, modes, and formats.
* It can automate the encryption and decryption processes for the users, without requiring them to perform any manual actions or install any software or plug-ins on their devices.
* It can monitor and audit the encryption activities and incidents, and provide visibility and accountability for the data protection and compliance status.
* It can reduce the human errors or negligence that may compromise the encryption security, such as losing or sharing the keys, forgetting or reusing the passwords, or sending the data to the wrong recipients.
References:
* Encryption in the Hands of End Users - ISACA, section 2: "A key goal of encryption is to protect the file even when direct access is possible or the transfer is intercepted."
* The Complexity Conundrum: Simplifying Data Security - ISACA, section 3: "Centrally managed encryption solutions can help enterprises overcome these challenges by providing a unified platform for encrypting data across different environments and applications."
* Email Encryption: What You Need to Know - Lifewire, section 1: "Email encryption is a way of protecting your email messages from being read by anyone other than the intended recipients."
NEW QUESTION # 111
As part of a major data discovery initiative to identify personal data across the organization, the project team has identified the proliferation of personal data held as unstructured data as a major risk. What should be done FIRST to address this situation?
- A. Identify who has access to sensitive unstructured data.
- B. Classify sensitive unstructured data.
- C. Identify sensitive unstructured data at the point of creation.
- D. Assign an owner to sensitive unstructured data.
Answer: B
Explanation:
Explanation
Classifying sensitive unstructured data should be done first to address the situation of the proliferation of personal data held as unstructured data, as it helps to identify the types, locations, and owners of the data, and to apply the appropriate privacy controls and measures based on the data classification level. Classifying sensitive unstructured data also facilitates the data discovery, data minimization, data retention, and data disposal processes. References: 2 Domain 3, Task 2; 5 Page 9
NEW QUESTION # 112
Which of the following is the GREATEST obstacle to conducting a privacy impact assessment (PIA)?
- A. The value proposition of a PIA is not understood by management.
- B. PIAs need to be performed many times in a year.
- C. The organization lacks knowledge of PIA methodology.
- D. Conducting a PIA requires significant funding and resources.
Answer: C
NEW QUESTION # 113
Which of the following features should be incorporated into an organization's technology stack to meet privacy requirements related to the rights of data subjects to control their personal data?
- A. Allowing system administrators to manage data access
- B. Establishing a data privacy customer service bot for individuals
- C. Providing system engineers the ability to search and retrieve data
- D. Allowing individuals to have direct access to their data
Answer: D
Explanation:
Any organization collecting information about EU residents is required to operate with transparency in collecting and using their personal information. Chapter III of the GDPR defines eight data subject rights that have become foundational for other privacy regulations around the world:
Right to access personal data. Data subjects can access the data collected on them.
NEW QUESTION # 114
Which of the following BEST enables an organization to ensure consumer credit card numbers are accurately captured?
- A. Input reference controls
- B. Access controls
- C. Input validation controls
- D. Reconciliation controls
Answer: C
Explanation:
Explanation
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.
References: Luhn algorithm, Credit card number, Bank card number, SQL injection, Cross-site scripting
NEW QUESTION # 115
Which of the following is the BEST control to secure application programming interfaces (APIs) that may contain personal information?
- A. Sharing only digitally signed APIs
- B. Encrypting APIs with the organization's private key
- C. Restricting access to authorized users
- D. Requiring nondisclosure agreements (NDAs) when sharing APIs
Answer: C
NEW QUESTION # 116
Which of the following processes BEST enables an organization to maintain the quality of personal data?
- A. Encrypting personal data at rest
- B. Implementing routine automatic validation
- C. Maintaining hashes to detect changes in data
- D. Updating the data quality standard through periodic review
Answer: B
Explanation:
Explanation
The best way to maintain the quality of personal data is to implement routine automatic validation, which is a process of checking the accuracy, completeness, consistency, and timeliness of the data using automated tools or scripts. Routine automatic validation can help identify and correct any errors, anomalies, or discrepancies in the data, as well as ensure that the data meets the specified quality standards and requirements. Routine automatic validation can also help improve the efficiency and reliability of the data processing and analysis12.
References:
* CDPSE Exam Content Outline, Domain 3 - Data Lifecycle (Data Quality), Task 2: Implement data quality measures3.
* CDPSE Review Manual, Chapter 3 - Data Lifecycle, Section 3.2 - Data Quality4.
NEW QUESTION # 117
Which of the following is MOST important to consider when managing changes to the provision of services by a third party that processes personal data?
- A. Changes to current information architecture
- B. Updates to data life cycle policy
- C. Modifications to data quality standards
- D. Business impact due to the changes
Answer: D
Explanation:
Explanation
The most important thing to consider when managing changes to the provision of services by a third party that processes personal data is the business impact due to the changes. Changes to the provision of services by a third party can affect the organization's ability to meet its business objectives and legal obligations related to data processing activities. For example, changes to the service level agreement (SLA), the scope of services, the security measures, the location of servers, etc., can have implications for the quality, availability, confidentiality, integrity, and compliance of personal data processing. Therefore, an IT privacy practitioner should assess and evaluate the business impact due to the changes, and ensure that they are aligned with the organization's privacy policies and applicable privacy regulations and standards. References: : CDPSE Review Manual (Digital Version), page 41
NEW QUESTION # 118
Which of the following is the BEST approach for a local office of a global organization faced with multiple privacy-related compliance requirements?
- A. Focus on global compliance before meeting local requirements.
- B. Focus on requirements with the highest organizational impact.
- C. Focus on local standards before meeting global compliance.
- D. Focus on developing a risk action plan based on audit reports.
Answer: C
NEW QUESTION # 119
The MOST effective way to incorporate privacy by design principles into applications is to include privacy requirements in.
- A. senior management approvals.
- B. software development practices.
- C. software testing guidelines.
- D. secure coding practices
Answer: B
Explanation:
Explanation
The most effective way to incorporate privacy by design principles into applications is to include privacy requirements in software development practices, because this ensures that privacy is considered and integrated from the early stages of the design process and throughout the entire lifecycle of the application. Software development practices include activities such as defining the scope, objectives, and specifications of the application, identifying and analyzing the privacy risks and impacts, selecting and implementing the appropriate privacy-enhancing technologies and controls, testing and validating the privacy functionality and performance, and monitoring and reviewing the privacy compliance and effectiveness of the application. By including privacy requirements in software development practices, the organization can achieve a proactive, preventive, and embedded approach to privacy that aligns with the privacy by design principles.
References:
CDPSE Review Manual, 2023 Edition, Domain 2: Privacy Architecture, Section 2.1.2: Privacy Requirements, p. 75 CDPSE Review Manual, 2023 Edition, Domain 2: Privacy Architecture, Section 2.2.1: Privacy by Design Methodology, p. 79-80 The 7 Principles of Privacy by Design | Blog | OneTrust1
NEW QUESTION # 120
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