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NEW QUESTION # 19
Which of the following is a PRIMARY objective of performing a privacy impact assessment (PIA) prior to onboarding a new Software as a Service (SaaS) provider for a customer relationship management (CRM) system?
- A. To assess the risk associated with personal data usage
- B. To identify controls to mitigate data privacy risks
- C. To classify personal data according to the data classification scheme
- D. To determine the service provider's ability to maintain data protection controls
Answer: B
Explanation:
Explanation
A primary objective of performing a privacy impact assessment (PIA) prior to onboarding a new Software as a Service (SaaS) provider for a customer relationship management (CRM) system is to identify controls to mitigate data privacy risks, such as data breaches, unauthorized access, misuse or loss of data. A PIA would help to evaluate the potential privacy impacts of using a new SaaS provider for CRM data processing activities, such as collecting, storing, analyzing or transferring customer data, and to implement appropriate controls to mitigate those impacts, such as encryption, access control, backup, audit trail or contractual clauses. A PIA would also help to ensure compliance with privacy principles, laws and regulations, and alignment with customer expectations and preferences. The other options are not primary objectives of performing a PIA prior to onboarding a new SaaS provider for CRM data processing activities. Classifying personal data according to the data classification scheme is an activity that may be part of a PIA process, but it is not an objective in itself. Assessing the risk associated with personal data usage is an activity that may be part of a PIA process, but it is not an objective in itself. Determining the service provider's ability to maintain data protection controls is an activity that may be part of a PIA process, but it is not an objective in itself1, p. 67 References: 1: CDPSE Review Manual (Digital Version)
NEW QUESTION # 20
Which of the following is the MOST important consideration when using advanced data sanitization methods to ensure privacy data will be unrecoverable?
- A. Type of media
- B. Regulatory compliance requirements
- C. Subject matter expertise
- D. Location of data
Answer: A
Explanation:
Explanation
Data sanitization is a process of permanently erasing or destroying data from a storage device or media to prevent unauthorized access or recovery of the data. Data sanitization methods can include physical destruction, degaussing, overwriting, encryption or cryptographic erasure. The most important consideration when using advanced data sanitization methods to ensure privacy data will be unrecoverable is the type of media on which the data is stored, as different media types may require different methods or techniques to achieve effective sanitization. For example, physical destruction may be suitable for optical disks or tapes, but not for solid state drives (SSDs) or flash memory devices. Degaussing may be effective for magnetic disks or tapes, but not for optical disks or SSDs. Overwriting may work for hard disk drives (HDDs) or SSDs, but not for tapes or optical disks. Encryption or cryptographic erasure may be applicable for any media type, but may require additional security measures to protect the encryption keys or certificates. The other options are not as important as the type of media when using advanced data sanitization methods. Subject matter expertise may be helpful, but not essential, as long as the appropriate method is selected and applied correctly. Regulatory compliance requirements may influence the choice of method, but not necessarily determine it, as different methods may meet different standards or criteria. Location of data may affect the feasibility or cost of applying a method, but not its effectiveness or suitability., p. 93-94 References: : CDPSE Review Manual (Digital Version)
NEW QUESTION # 21
Which of the following is the BEST way to ensure privacy considerations are included when working with vendors?
- A. Including privacy requirements in the request for proposal (RFP) process
- B. Requiring vendors to complete privacy awareness training
- C. Including privacy requirements in vendor c tracts
- D. Monitoring privacy-related service level agreements (SLAS)
Answer: C
Explanation:
Explanation
Including privacy requirements in vendor contracts is the best way to ensure privacy considerations are included when working with vendors because it establishes the obligations, expectations and responsibilities of both parties regarding the protection of personal data. It also provides a legal basis for enforcing compliance and resolving disputes. Including privacy requirements in the request for proposal (RFP) process, monitoring privacy-related service level agreements (SLAs) and requiring vendors to complete privacy awareness training are helpful measures, but they do not guarantee that vendors will adhere to the privacy requirements or that they will be held accountable for any violations.
References:
* CDPSE Review Manual (Digital Version), Domain 1: Privacy Governance, Task 1.7: Participate in the management and evaluation of contracts, service levels and practices of vendors and other external parties1
* CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 2: Privacy Governance, Section: Vendor Management2
NEW QUESTION # 22
In which of the following should the data record retention period be defined and established?
- A. Data quality standard
- B. Data recovery procedures
- C. Data management plan
- D. Data record model
Answer: C
NEW QUESTION # 23
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. A remote employee placing communication software on a company server
- D. An employee loading personal information on a company laptop
Answer: D
Explanation:
Explanation
The greatest privacy risk for client-side application processing is an employee loading personal information on a company laptop. Client-side application processing refers to performing data processing operations on the user's device or browser, rather than on a server or cloud. This can improve performance and user experience, but also pose privacy risks if the user's device is lost, stolen, hacked, or infected with malware. An employee loading personal information on a company laptop is exposing that information to potential threats on the client-side, such as unauthorized access, use, disclosure, modification, or loss. Therefore, an organization should implement appropriate security measures to protect personal information on client-side devices, such as encryption, authentication, authorization, logging, monitoring, etc. References: : CDPSE Review Manual (Digital Version), page 153
NEW QUESTION # 24
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. Identify sensitive unstructured data at the point of creation.
- C. Classify sensitive unstructured data.
- D. Assign an owner to sensitive unstructured data.
Answer: C
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 # 25
What is the BEST way for an organization to maintain the effectiveness of its privacy breach incident response plan?
- A. Involve the privacy office in an organizational review of the incident response plan.
- B. Hire a third party to perform a review of data privacy processes.
- C. Conduct annual data privacy tabletop exercises.
- D. Require security management to validate data privacy security practices.
Answer: C
Explanation:
Explanation
The best way for an organization to maintain the effectiveness of its privacy breach incident response plan is to conduct annual data privacy tabletop exercises. A data privacy tabletop exercise is a simulated scenario that tests the organization's ability to respond to a privacy breach incident, such as a data breach, leak, or misuse.
A data privacy tabletop exercise involves key stakeholders, such as the privacy office, the information security team, the legal counsel, the public relations team, etc., who role-play their actions and decisions based on the scenario. A data privacy tabletop exercise helps to evaluate and improve the organization's privacy breach incident response plan, such as identifying gaps or weaknesses, validating roles and responsibilities, verifying procedures and protocols, assessing communication and coordination, etc. References: : CDPSE Review Manual (Digital Version), page 83
NEW QUESTION # 26
An organization is creating a personal data processing register to document actions taken with personal data.
Which of the following categories should document controls relating to periods of retention for personal data?
- A. Data storage
- B. Data acquisition
- C. Data input
- D. Data archiving
Answer: D
Explanation:
Explanation
However, the risks associated with long-term retention have compelled organizations to consider alternatives; one is data archival, the process of preparing data for long-term storage. When organizations are bound by specific laws to retain data for many years, archival provides a viable opportunity to remove data from online transaction systems to other systems or media.
Data archiving is the process of moving data that is no longer actively used to a separate storage device for long-term retention. Data archiving helps to reduce the cost and complexity of data storage, improve the performance and availability of data systems, and comply with data retention policies and regulations. Data archiving should document controls relating to periods of retention for personal data, such as the criteria for determining the retention period, the procedures for deleting or anonymizing data after the retention period expires, and the mechanisms for ensuring the integrity and security of archived data. References: : CDPSE Review Manual (Digital Version), page 123
NEW QUESTION # 27
Which of the following is MOST important when developing an organizational data privacy program?
- A. Following an established privacy framework
- B. Obtaining approval from process owners
- C. Performing an inventory of all data
- D. Profiling current data use
Answer: C
NEW QUESTION # 28
Which of the following techniques mitigates design flaws in the application development process that may contribute to potential leakage of personal data?
- A. User acceptance testing (UAT)
- B. Software hardening
- C. Web application firewall (WAF)
- D. Patch management
Answer: A
NEW QUESTION # 29
Which of the following is a PRIMARY consideration to protect against privacy violations when utilizing artificial intelligence (AI) driven business decisions?
- A. Defining the intended objectives
- B. Verifying the data subjects have consented to the processing
- C. Ensuring proper data sets are used to train the models
- D. De-identifying the data to be analyzed
Answer: C
Explanation:
Explanation
The primary consideration to protect against privacy violations when utilizing artificial intelligence (AI) driven business decisions is ensuring proper data sets are used to train the models. AI is a technology that enables machines or systems to perform tasks that normally require human intelligence, such as reasoning, learning, decision making, etc. AI relies on large amounts of data to train its models and algorithms to perform these tasks. However, if the data sets used to train the models are inaccurate, incomplete, biased, or outdated, they can result in privacy violations, such as discrimination, profiling, manipulation, or harm to the data subjects. Therefore, an IT privacy practitioner should ensure that the data sets used to train the models are proper, meaning that they are relevant, representative, reliable, and respectful of the data subjects' rights and interests. References: : CDPSE Review Manual (Digital Version), page 141
NEW QUESTION # 30
What is the PRIMARY means by which an organization communicates customer rights as it relates to the use of their personal information?
- A. Mailing rights documentation to customers
- B. Publishing a privacy notice
- C. Distributing a privacy rights policy
- D. Gaining consent when information is collected
Answer: B
Explanation:
Explanation
The primary means by which an organization communicates customer rights as it relates to the use of their personal information is publishing a privacy notice. A privacy notice is a document that informs the customers about how their personal information is collected, used, shared, stored, and protected by the organization, as well as what rights they have regarding their personal information, such as access, rectification, erasure, portability, objection, etc. A privacy notice should be clear, concise, transparent, and easily accessible to the customers, and should comply with the applicable privacy regulations and standards. A privacy notice helps to establish trust and transparency between the organization and the customers, and enables the customers to exercise their rights and choices over their personal information. References: : CDPSE Review Manual (Digital Version), page 39
NEW QUESTION # 31
Which of the following is the BEST practice to protect data privacy when disposing removable backup media?
- A. Data encryption
- B. Data masking
- C. Data scrambling
- D. Data sanitization
Answer: D
Explanation:
Explanation
The best practice to protect data privacy when disposing removable backup media is B. Data sanitization.
A comprehensive explanation is:
Data sanitization is the process of permanently and irreversibly erasing or destroying the data on a storage device or media, such as a hard drive, a USB drive, a CD/DVD, etc. Data sanitization ensures that the data cannot be recovered or reconstructed by any means, even by using specialized software or hardware tools.
Data sanitization is also known as data wiping, data erasure, data destruction, or data disposal.
Data sanitization is the best practice to protect data privacy when disposing removable backup media because it prevents unauthorized access, disclosure, theft, or misuse of the sensitive or confidential data that may be stored on the media. Data sanitization also helps to comply with the legal and regulatory requirements and standards for data protection and privacy, such as the General Data Protection Regulation (GDPR), the Health Insurance Portability and Accountability Act (HIPAA), the Payment Card Industry Data Security Standard (PCI DSS), etc.
There are different methods and techniques for data sanitization, depending on the type and format of the storage device or media. Some of the common methods are:
* Overwriting: Overwriting replaces the existing data on the device or media with random or meaningless data, such as zeros, ones, or patterns. Overwriting can be done multiple times to increase the level of security and assurance. Overwriting is suitable for magnetic media, such as hard disk drives (HDDs) or tapes.
* Degaussing: Degaussing exposes the device or media to a strong magnetic field that disrupts and destroys the magnetic structure and alignment of the data. Degaussing renders the device or media unusable and unreadable. Degaussing is suitable for magnetic media, such as hard disk drives (HDDs) or tapes.
* Physical Destruction: Physical destruction involves applying physical force or damage to the device or media that breaks it into small pieces or shreds it. Physical destruction can be done by using mechanical tools, such as shredders, crushers, drills, hammers, etc., or by using thermal methods, such as incineration, melting, etc. Physical destruction is suitable for any type of media, such as hard disk drives (HDDs), solid state drives (SSDs), USB drives, CDs/DVDs, etc.
Data encryption (A) is not a good practice to protect data privacy when disposing removable backup media because it does not erase or destroy the data on the media. Data encryption only transforms the data into an unreadable format that can only be accessed with a key or a password. However, if the key or password is lost, stolen, compromised, or guessed by an attacker, the data can still be decrypted and exposed. Data encryption is more suitable for protecting data in transit or at rest, but not for disposing data.
Data scrambling is not a good practice to protect data privacy when disposing removable backup media because it does not erase or destroy the data on the media. Data scrambling only rearranges the order of the bits or bytes of the data to make it appear random or meaningless. However, if the algorithm or pattern of scrambling is known or discovered by an attacker, the data can still be unscrambled and restored. Data scrambling is more suitable for obfuscating data for testing or debugging purposes, but not for disposing data.
Data masking (D) is not a good practice to protect data privacy when disposing removable backup media because it does not erase or destroy the data on the media. Data masking only replaces some parts of the data with fictitious or anonymized values to hide its true identity or meaning. However, if the original data is still stored somewhere else or if the masking technique is weak or reversible by an attacker, the data can still be unmasked and revealed. Data masking is more suitable for protecting data in use or in analysis, but not for disposing data.
References:
* What Is Data Sanitization?1
* How to securely erase hard drives (HDDs) and solid state drives (SSDs)2
* Secure Data Disposal & Destruction: 6 Methods to Follow3
NEW QUESTION # 32
Which of the following is the PRIMARY reason to complete a privacy impact assessment (PIA)?
- A. To understand privacy risks
- B. To comply with consumer regulatory requirements
- C. To classify personal data
- D. To establish privacy breach response procedures
Answer: B
NEW QUESTION # 33
It is MOST important to consider privacy by design principles during which phase of the software development life cycle (SDLC)?
- A. Application design
- B. Requirements definition
- C. Testing
- D. Implementation
Answer: C
NEW QUESTION # 34
What is the BES T way for an organization to maintain the effectiveness of its privacy breach incident response plan?
* Require security management to validate data privacy security practices.
* Conduct annual data privacy tabletop exercises
- A. Hire a third party to perform a review of data privacy processes.
- B. Involve the privacy office in an organizational review of the incident response plan.
Answer: B
Explanation:
Explanation
The best way for an organization to maintain the effectiveness of its privacy breach incident response plan is to conduct annual data privacy tabletop exercises. A tabletop exercise is a simulated scenario that tests the organization's ability to respond to a privacy breach incident in a realistic and interactive way. A tabletop exercise can help the organization to evaluate the roles and responsibilities of the incident response team, identify the gaps and weaknesses in the plan, improve the communication and coordination among the stakeholders, and update the plan based on the lessons learned and best practices12. A tabletop exercise can also enhance the awareness and readiness of the organization to handle privacy breach incidents in a timely and effective manner3. References:
* ISACA CDPSE Review Manual, Chapter 4, Section 4.3.2
* ISACA Journal, Volume 4, 2019, "Tabletop Exercises: Three Sample Scenarios"
* ISACA Journal, Volume 6, 2017, "Privacy Breach Response: Preparing for the Inevitable"
NEW QUESTION # 35
A multinational corporation is planning a big data initiative to help with critical business decisions. Which of the following is the BEST way to ensure personal data usage is standardized across the entire organization?
- A. Develop a data dictionary.
- B. Encrypt all sensitive data.
- C. De-identify all data.
- D. Perform data discovery.
Answer: A
Explanation:
Explanation
A data dictionary is a document that defines and describes the data elements, attributes, formats, sources, destinations, purposes and relationships of a data set or system. A data dictionary would be the best way to ensure personal data usage is standardized across the entire organization, as it would provide a common and consistent understanding and reference for how personal data is collected, used, disclosed and transferred within and outside the organization. A data dictionary would also help to ensure compliance with privacy principles, such as accuracy, transparency and accountability. The other options are not as effective as developing a data dictionary in ensuring personal data usage is standardized across the entire organization.
De-identify all data is a technique that removes or modifies direct and indirect identifiers in a data set to prevent or limit the identification of the data subjects, but it does not ensure standardization or consistency of personal data usage across the organization. Encrypt all sensitive data is a technique that transforms plain text data into cipher text using an algorithm and a key, making it unreadable by unauthorized parties, but it does not ensure standardization or consistency of personal data usage across the organization. Perform data discovery is a process of identifying and locating personal data within an organization's systems, databases, applications or files, but it does not ensure standardization or consistency of personal data usage across the organization1, p. 69-70 References: 1: CDPSE Review Manual (Digital Version)
NEW QUESTION # 36
When using anonymization techniques to prevent unauthorized access to personal data, which of the following is the MOST important consideration to ensure the data is adequately protected?
- A. The key must be kept separate and distinct from the data it protects.
- B. The data must be stored in locations protected by data loss prevention (DLP) technology.
- C. The key must be a combination of alpha and numeric characters.
- D. The data must be protected by multi-factor authentication.
Answer: A
Explanation:
Explanation
Anonymization is a technique that removes or modifies personal data in such a way that it can no longer be attributed to a specific data subject. Anonymization can be achieved by various methods, such as encryption, pseudonymization, aggregation, generalization, etc. When using anonymization techniques to prevent unauthorized access to personal data, the most important consideration to ensure the data is adequately protected is that the key must be kept separate and distinct from the data it protects. The key is a piece of information that is used to reverse the anonymization process and restore the original personal data. The key must be stored and managed in a secure location that is different from where the anonymized data is stored and processed. This way, even if the anonymized data is compromised, the key cannot be accessed or used to re-identify the data subjects. References: : CDPSE Review Manual (Digital Version), page 29
NEW QUESTION # 37
When a government's health division established the complete privacy regulation for only the health market, which privacy protection reference model is being used?
- A. Co-regulatory
- B. Self-regulatory
- C. Comprehensive
- D. Sectoral
Answer: C
NEW QUESTION # 38
Which of the following should be the FIRST consideration when selecting a data sanitization method?
- A. Risk tolerance
- B. Implementation cost
- C. Industry standards
- D. Storage type
Answer: D
NEW QUESTION # 39
What is the BEST method to protect customers' personal data that is forwarded to a central system for analysis?
- A. Pseudonymization
- B. Deletion
- C. Anonymization
- D. Encryption
Answer: D
NEW QUESTION # 40
Which of the following is an IT privacy practitioner's BEST recommendation to reduce privacy risk before an organization provides personal data to a third party?
- A. Tokenization
- B. Aggregation
- C. Anonymization
- D. Encryption
Answer: C
Explanation:
Explanation
Anonymization is a technique that removes or modifies all identifiers in a data set to prevent or limit the identification of the data subjects. Anonymization is an IT privacy practitioner's best recommendation to reduce privacy risk before an organization provides personal data to a third party, as it would protect the privacy of the data subjects by reducing the linkability of the data set with their original identity, and also comply with the data minimization principle that requires limiting the collection, storage and processing of personal data to what is necessary and relevant for the intended purposes. Anonymization would also preserve some characteristics or patterns of the original data that can be used for analysis or research purposes by the third party, without compromising the accuracy or quality of the results. The other options are not as effective as anonymization in reducing privacy risk before an organization provides personal data to a third party.
Tokenization is a technique that replaces sensitive or confidential data with non-sensitive tokens or placeholders that do not reveal the original data, but it does not prevent or limit the identification of the data subjects, as tokens can be reversed or linked back to the original data using a tokenization system or key.
Aggregation is a technique that combines individual data into groups or categories that do not reveal the identity of the data subjects, but it may not prevent or limit the identification of the data subjects, as aggregated data can be de-aggregated or re-identified using other sources of information or techniques. Encryption is a technique that transforms plain text data into cipher text using an algorithm and a key, making it unreadable by unauthorized parties, but it does not prevent or limit the identification of the data subjects, as encrypted data can be decrypted or linked back to the original data using an encryption system or key1, p. 74-75 References: 1: CDPSE Review Manual (Digital Version)
NEW QUESTION # 41
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