[Q143-Q165] CIPM by IAPP Actual Free Exam Questions And Answers [UPDATED 2025]

CIPM by IAPP Actual Free Exam Questions And Answers [UPDATED 2025]

CIPM Questions Truly Valid For Your IAPP Exam!

NEW QUESTION # 143
Which of the following is an example of Privacy by Design (PbD)?

• A. A company hires a professional to structure a privacy program that anticipates the increasing demands of new laws.
• B. The human resources group develops a training program for employees to become certified in privacy policy.
• C. The information technology group uses privacy considerations to inform the development of new networking software.
• D. A labor union insists that the details of employers' data protection methods be documented in a new contract.

Answer: D

NEW QUESTION # 144
SCENARIO
Please use the following to answer the next question
You were recently hired by InStyte Date Corp as a privacy manager to help InStyle Data Corp become compliant with a new data protection law The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue companies that don t comply with the new law You are paved with a security manager and tasked with reviewing InStyle Data Corp s current state and advising the business how it can meet the "reasonable and appropriate security" requirement InStyle Data Corp has grown rapidly and has not kept a data inventory or completed a data mapping InStyte Data Corp has also developed security-related policies ad hoc and many have never been implemented The various teams involved in the creation and testing of InStyle Data Corp s products experience significant turnover and do not have well defined roles There's little documentation addressing what personal data is processed by which product and for what purpose Work needs to begin on this project immediately so that InStyle Data Corp can become compliant by the time the law goes into effect. You and you partner discover that InStyle Data Corp regularly sends files containing sensitive personal data back to its customers through email sometimes using InStyle Data Corp employees personal email accounts. You also team that InStyle Data Corp s privacy and information security teams are not informed of new personal data flows, new products developed by InStyte Data Corp that process personal data, or updates to existing InStyle Data Corp products that may change what or how the personal data is processed until after the product or update has gone have.
Through a review of InStyle Date Corp's test and development environment logs, you discover InStyle Data Corp sometimes gives login credentials to any InStyle Data Corp employee or contractor who requests them.
The test environment only contains dummy data but the development environment contains personal data including Social Security Numbers, hearth ^formation and financial information All credentialed InStyle Data Corp employees and contractors have the ability to after and delete personal data in both environments regardless of their role or what project they are working on.
You and your partner provide a gap assessment citing the issues you spotted, along with recommended remedial actions and a method to measure implementation InStyle Data Corp implements all of the recommended security controls You review the processes roles, controls and measures taken to appropriately protect the personal data at every stop However, you realize there is no plan for monitoring and nothing in place addressing sanctions for violations of the updated policies and procedures InStyle Data Corp pushes back, stating they do not have the resources for such monitoring.
What aspect of the data management life cycle will still be unaddressed it you cannot find the resources to become compliant?

• A. Access management
• B. Irretrievability
• C. Enforcement
• D. Auditability.

Answer: C

Explanation:
Explanation
The aspect of the data management life cycle that will still be unaddressed if you cannot find the resources to become compliant is enforcement. Enforcement means ensuring that the data policies and procedures are followed by all data users and stakeholders, and that any violations or deviations are detected, reported, and corrected. Enforcement also involves imposing sanctions or penalties for non-compliance, such as revoking access rights, issuing warnings, or terminating contracts. Without enforcement, the data security measures that you implemented may not be effective or sustainable, as there would be no accountability or deterrence for data misuse or abuse1, 2.
To address the enforcement aspect of the data management life cycle, you should try to convince InStyle Data Corp of the importance and benefits of monitoring and sanctioning data activities. You should explain that monitoring can help identify and prevent data breaches, errors, or inefficiencies, as well as demonstrate compliance with the new data protection law. You should also explain that sanctioning can help enforce data discipline and responsibility, as well as deter potential violators or malicious actors. You should also propose some possible ways to allocate or optimize the resources for monitoring and sanctioning, such as automating some processes, outsourcing some tasks, or prioritizing some data types or sources1, 2.
References: Data Lifecycle Management: A 2023 Guide for Your Business - Cloudwards, 6 Data Lifecycle Stages: Data Cycle Management Guide

NEW QUESTION # 145
What is the name for the privacy strategy model that describes delegated decision making?

• A. De-centralized.
• B. De-functionalized.
• C. Matrix.
• D. Hybrid.

Answer: C

Explanation:
A matrix is a type of organizational structure that involves delegated decision making. In a matrix structure, employees report to more than one manager or leader, usually based on different functions or projects. For example, a software developer may report to both a product manager and a technical manager. A matrix structure allows for more flexibility, collaboration, and innovation in complex and dynamic environments.
The other options are not examples of delegated decision making structures. A de-centralized structure involves distributing decision making authority across different levels or units of the organization, rather than concentrating it at the top. A de-functionalized structure involves breaking down functional silos and creating cross-functional teams or processes. A hybrid structure involves combining elements of different types of structures, such as functional, divisional, or matrix.

NEW QUESTION # 146
Under the GDPR, what obligation does a data controller or processor have after appointing a data protection officer (DPO)?

• A. To ensure that the DPO acts as the sole point of contact for individuals' questions about their personal data.
• B. To ensure that the DPO receives sufficient instructions regarding the exercise of their defined tasks.
• C. To provide resources necessary to carry out the defined tasks of the DPO and to maintain their expert knowledge.
• D. To submit for approval to the DPO a code of conduct to govern organizational practices and demonstrate compliance with data protection principles.

Answer: C

NEW QUESTION # 147
SCENARIO
Please use the following to answer the next QUESTION:
It's just what you were afraid of. Without consulting you, the information technology director at your organization launched a new initiative to encourage employees to use personal devices for conducting business. The initiative made purchasing a new, high-specification laptop computer an attractive option, with discounted laptops paid for as a payroll deduction spread over a year of paychecks. The organization is also paying the sales taxes. It's a great deal, and after a month, more than half the organization's employees have signed on and acquired new laptops. Walking through the facility, you see them happily customizing and comparing notes on their new computers, and at the end of the day, most take their laptops with them, potentially carrying personal data to their homes or other unknown locations. It's enough to give you data- protection nightmares, and you've pointed out to the information technology Director and many others in the organization the potential hazards of this new practice, including the inevitability of eventual data loss or theft.
Today you have in your office a representative of the organization's marketing department who shares with you, reluctantly, a story with potentially serious consequences. The night before, straight from work, with laptop in hand, he went to the Bull and Horn Pub to play billiards with his friends. A fine night of sport and socializing began, with the laptop "safely" tucked on a bench, beneath his jacket. Later that night, when it was time to depart, he retrieved the jacket, but the laptop was gone. It was not beneath the bench or on another bench nearby. The waitstaff had not seen it. His friends were not playing a joke on him. After a sleepless night, he confirmed it this morning, stopping by the pub to talk to the cleanup crew. They had not found it.
The laptop was missing. Stolen, it seems. He looks at you, embarrassed and upset.
You ask him if the laptop contains any personal data from clients, and, sadly, he nods his head, yes. He believes it contains files on about 100 clients, including names, addresses and governmental identification numbers. He sighs and places his head in his hands in despair.
What should you do first to ascertain additional information about the loss of data?

• A. Interview the person reporting the incident following a standard protocol.
• B. Call the police to investigate even if you are unsure a crime occurred.
• C. Investigate the background of the person reporting the incident.
• D. Check company records of the latest backups to see what data may be recoverable.

Answer: A

Explanation:
This answer is the best way to ascertain additional information about the loss of data, as it allows you to gather relevant facts and details from the person who witnessed or experienced the incident. A standard protocol for interviewing the person reporting the incident should include questions such as:
* When and where did the incident occur?
* What type and amount of data was involved?
* How was the data stored or protected on the laptop?
* Who else had access to or knowledge of the laptop or the data?
* What actions have been taken so far to recover or secure the laptop or the data?
* How did you discover or report the incident?
* Do you have any evidence or clues about who may have taken or accessed the laptop or the data?
* Do you have any other information that may be relevant or helpful for the investigation? Interviewing the person reporting the incident following a standard protocol can help you to establish a clear timeline and scope of the incident, identify potential sources of evidence, assess the level of risk and harm to the individuals and the organization, and determine the next steps for responding to and resolving the incident. References: IAPP CIPM Study Guide, page 87; ISO/IEC 27002:2013, section 16.1.4

NEW QUESTION # 148
SCENARIO
Please use the following to answer the next QUESTION:
As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically Questionable practices, including unauthorized sales of personal data to marketers.
Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that
"appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.
Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures.
He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.
The company has achieved a level of privacy protection that established new best practices for the industry.
What is a logical next step to help ensure a high level of protection?

• A. Focus on improving the incident response plan in preparation for any breaks in protection
• B. Brainstorm methods for developing an enhanced privacy framework
• C. Shift attention to privacy for emerging technologies as the company begins to use them
• D. Develop a strong marketing strategy to communicate the company's privacy practices

Answer: C

Explanation:
Explanation
Shifting attention to privacy for emerging technologies as the company begins to use them is a logical next step to help ensure a high level of protection. Emerging technologies, such as artificial intelligence, biometrics, blockchain, cloud computing, internet of things, etc., may pose new challenges and opportunities for privacy and data protection. They may involve new types, sources, uses, and flows of personal data that require different or additional safeguards and controls. They may also introduce new risks or impacts for individuals' rights and interests that require careful assessment and mitigation. Therefore, it is important for the company to consider and address the privacy implications of emerging technologies as they adopt or integrate them into their products, services, or processes.
The other options are not as logical or effective as shifting attention to privacy for emerging technologies for ensuring a high level of protection. Brainstorming methods for developing an enhanced privacy framework may not be necessary or feasible if the company already has established new best practices for the industry.
Developing a strong marketing strategy to communicate the company's privacy practices may not be sufficient or relevant for ensuring a high level of protection, as it may not reflect the actual state or quality of the privacy program. Focusing on improving the incident response plan in preparation for any breaks in protection may be too reactive or narrow in scope, as it may not cover other aspects or dimensions of privacy and data protection that require continuous monitoring and improvement.
For more information on privacy for emerging technologies, you can refer to these sources:
* [Privacy by Design in Emerging Technologies]
* [Privacy Challenges in Emerging Technologies]
* [Privacy Enhancing Technologies]

NEW QUESTION # 149
Which of the following is NOT a type of privacy program metric?

• A. Data enhancement metrics.
• B. Commercial metrics.
• C. Business enablement metrics.
• D. Value creation metrics.

Answer: D

Explanation:
Types of privacy program metrics include business enablement metrics, data enhancement metrics, and commercial metrics. Business enablement metrics measure the effectiveness of the privacy program in enabling the business to function without compromising privacy. Data enhancement metrics measure the effectiveness of the privacy program in enhancing data protection, such as through data minimization, access controls, and data security. Commercial metrics measure the effectiveness of the privacy program in creating value, such as through the development of new products, services, and customer experiences.
Privacy program metrics are used to assess the effectiveness of a privacy program and measure its progress. These metrics can include business enablement metrics, data enhancement metrics, and commercial metrics. Value creation metrics, however, are not typically used as privacy program metrics.

NEW QUESTION # 150
Which is TRUE about the scope and authority of data protection oversight authorities?

• A. The Office of the Privacy Commissioner (OPC) of Canada has the right to impose financial sanctions on violators
• B. The Asia-Pacific Economic Cooperation (APEC) Privacy Frameworks require all member nations to designate a national data protection authority
• C. All authority in the European Union rests with the Data Protection Commission (DPC)
• D. No one agency officially oversees the enforcement of privacy regulations in the United States

Answer: A

Explanation:
Explanation/Reference: https://www.priv.gc.ca/en/opc-actions-and-decisions/ar_index/201617/ar_201617/

NEW QUESTION # 151
SCENARIO
Please use the following to answer the next question:
Your organization, the Chicago (U.S.)-based Society for Urban Greenspace, has used the same vendor to operate all aspects of an online store for several years. As a small nonprofit, the Society cannot afford the higher-priced options, but you have been relatively satisfied with this budget vendor, Shopping Cart Saver (SCS). Yes, there have been some issues. Twice, people who purchased items from the store have had their credit card information used fraudulently subsequent to transactions on your site, but in neither case did the investigation reveal with certainty that the Society's store had been hacked. The thefts could have been employee-related.
Just as disconcerting was an incident where the organization discovered that SCS had sold information it had collected from customers to third parties. However, as Jason Roland, your SCS account representative, points out, it took only a phone call from you to clarify expectations and the "misunderstanding" has not occurred again.
As an information-technology program manager with the Society, the role of the privacy professional is only one of many you play. In all matters, however, you must consider the financial bottom line. While these problems with privacy protection have been significant, the additional revenues of sales of items such as shirts and coffee cups from the store have been significant. The Society's operating budget is slim, and all sources of revenue are essential.
Now a new challenge has arisen. Jason called to say that starting in two weeks, the customer data from the store would now be stored on a data cloud. "The good news," he says, "is that we have found a low-cost provider in Finland, where the data would also be held. So, while there may be a small charge to pass through to you, it won't be exorbitant, especially considering the advantages of a cloud." Lately, you have been hearing about cloud computing and you know it's fast becoming the new paradigm for various applications. However, you have heard mixed reviews about the potential impacts on privacy protection. You begin to research and discover that a number of the leading cloud service providers have signed a letter of intent to work together on shared conventions and technologies for privacy protection. You make a note to find out if Jason's Finnish provider is signing on.
What is the best way for your vendor to be clear about the Society's breach notification expectations?

• A. Include notification provisions in the vendor contract
• B. Arrange regular telephone check-ins reviewing expectations
• C. Send a memorandum of understanding on breach notification
• D. Email the regulations that require breach notifications

Answer: A

NEW QUESTION # 152
When building a data privacy program, what is a good starting point to understand the scope of privacy program needs?

• A. Perform Data Protection Impact Assessments (DPIAs).
• B. Complete a Data Inventory.
• C. Review Audits.
• D. Perform Risk Assessments

Answer: B

NEW QUESTION # 153
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. Develop a metric showing the number of initiatives launched without consultation and include it in reports, presentations, and consultation.
• B. Insist upon one-on-one consultation with each person who works around the privacy officer.
• C. Take your concerns straight to the Chief Executive Officer.
• D. Hold discussions with the department head of anyone who fails to consult with the privacy officer.

Answer: A

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 # 154
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. Hold discussions with the department head of anyone who fails to consult with the privacy officer.
• B. Insist upon one-on-one consultation with each person who works around 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: A

NEW QUESTION # 155
For an organization that has just experienced a data breach, what might be the least relevant metric for a company's privacy and governance team?

• A. The number of security patches applied to company devices.
• B. The number of employees who have completed data awareness training.
• C. The number of Privacy Impact Assessments that have been completed.
• D. The number of privacy rights requests that have been exercised.

Answer: A

Explanation:
The number of security patches applied to company devices might be the least relevant metric for a company's privacy and governance team after a data breach. While security patches are important for preventing future breaches, they do not directly measure the impact or response of the current breach. The other metrics are more relevant for assessing how the company handled the breach, such as how it complied with the privacy rights of affected individuals, how it evaluated the privacy risks of its systems, and how it trained its employees on data awareness. Reference: CIPM Study Guide, page 28.

NEW QUESTION # 156
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?
What analytic can be used to track the financial viability of the program as it develops?

• A. Cost basis
• B. Gap analysis
• C. Return on investment
• D. Breach impact modeling

Answer: C

NEW QUESTION # 157
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.
Based on the scenario, Nationwide Grill needs to create better employee awareness of the company's privacy program by doing what?

• A. Communicating to the staff more often.
• B. Improving inter-departmental cooperation.
• C. Varying the modes of communication.
• D. Requiring acknowledgment of company memos.

Answer: C

Explanation:
Explanation
This answer is the best way to create better employee awareness of the company's privacy program, as it can increase the effectiveness and retention of the information by appealing to different learning styles and preferences. Varying the modes of communication can include using different formats and channels, such as posters, emails, memos, videos, webinars, podcasts, newsletters, quizzes, games or interactive modules.
Varying the modes of communication can also help to avoid information overload or duplication, which may cause employees to ignore or disregard the privacy messages. References: IAPP CIPM Study Guide, page 90; ISO/IEC 27002:2013, section 7.2.2

NEW QUESTION # 158
SCENARIO
Please use the following to answer the next QUESTION:
Your organization, the Chicago (U.S.)-based Society for Urban Greenspace, has used the same vendor to operate all aspects of an online store for several years. As a small nonprofit, the Society cannot afford the higher-priced options, but you have been relatively satisfied with this budget vendor, Shopping Cart Saver (SCS). Yes, there have been some issues. Twice, people who purchased items from the store have had their credit card information used fraudulently subsequent to transactions on your site, but in neither case did the investigation reveal with certainty that the Society's store had been hacked. The thefts could have been employee-related.
Just as disconcerting was an incident where the organization discovered that SCS had sold information it had collected from customers to third parties. However, as Jason Roland, your SCS account representative, points out, it took only a phone call from you to clarify expectations and the "misunderstanding" has not occurred again.
As an information-technology program manager with the Society, the role of the privacy professional is only one of many you play. In all matters, however, you must consider the financial bottom line. While these problems with privacy protection have been significant, the additional revenues of sales of items such as shirts and coffee cups from the store have been significant. The Society's operating budget is slim, and all sources of revenue are essential.
Now a new challenge has arisen. Jason called to say that starting in two weeks, the customer data from the store would now be stored on a data cloud. "The good news," he says, "is that we have found a low-cost provider in Finland, where the data would also be held. So, while there may be a small charge to pass through to you, it won't be exorbitant, especially considering the advantages of a cloud." Lately, you have been hearing about cloud computing and you know it's fast becoming the new paradigm for various applications. However, you have heard mixed reviews about the potential impacts on privacy protection. You begin to research and discover that a number of the leading cloud service providers have signed a letter of intent to work together on shared conventions and technologies for privacy protection. You make a note to find out if Jason's Finnish provider is signing on.
What is the best way to prevent the Finnish vendor from transferring data to another party?

• A. Lock the data down in its current location
• B. Restrict the vendor to using company security controls
• C. Offer company resources to assist with the processing
• D. Include transfer prohibitions in the vendor contract

Answer: D

Explanation:
This answer is the best way to prevent the Finnish vendor from transferring data to another party, as it can establish clear and binding terms and conditions for both parties regarding their roles and responsibilities for data processing activities. Including transfer prohibitions in the vendor contract can help to define the scope, purpose, duration and type of data processing, as well as the rights and obligations of both parties. The contract can also specify that the vendor is not allowed to share, disclose or transfer the data to any third party without the prior consent or authorization of the organization, and that any breach of this clause may result in legal actions, penalties or termination of the contract.

NEW QUESTION # 159
SCENARIO
Please use the following to answer the next QUESTION:
As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically Questionable practices, including unauthorized sales of personal data to marketers. Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that "appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.
Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures. He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.
The CEO likes what he's seen of the company's improved privacy program, but wants additional assurance that it is fully compliant with industry standards and reflects emerging best practices. What would best help accomplish this goal?

• A. Creation of a self-certification framework based on company policies
• B. An internal audit team accountable to upper management
• C. Revision of the strategic plan to provide a system of technical controls
• D. An external audit conducted by a panel of industry experts

Answer: C

NEW QUESTION # 160
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 can Sanjay do to minimize the risks of offering the product in Europe?

• A. Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released.
• B. Sanjay should document the data life cycle of the data collected by the Handy Helper.
• C. Sanjay should advise the distributor that Omnipresent Omnimedia has certified to the Privacy Shield Framework and there should be no issues.
• D. Sanjay should write a privacy policy to include with the Handy Helper user guide.

Answer: B

NEW QUESTION # 161
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!" Since it is too late to restructure the contract with the vendor or prevent the app from being deployed, what is the best step for you to take next?

• A. Insist on an audit of the vendor's privacy procedures and safeguards.
• B. Implement a more comprehensive suite of information security controls than the one used by the vendor.
• C. Develop security protocols for the vendor and mandate that they be deployed.
• D. Ask the vendor for verifiable information about their privacy protections so weaknesses can be identified.

Answer: D

Explanation:
This answer is the best step to take next, as it can help you to assess the current state of the vendor's privacy practices and determine if they meet the organization's standards and expectations, as well as the applicable laws and regulations. Asking the vendor for verifiable information about their privacy protections can include requesting documentation, evidence or demonstration of how they collect, use, store, protect, share and dispose of personal data, what policies and procedures they have in place, what technical and organizational measures they implement, what certifications or audits they have obtained or undergone, and how they handle any privacy incidents or breaches. Based on this information, you can identify any weaknesses or gaps in the vendor's privacy protections and recommend or require any improvements or corrections before the app is deployed. Reference: IAPP CIPM Study Guide, page 82; ISO/IEC 27002:2013, section 15.1.2

NEW QUESTION # 162
SCENARIO
Please use the following to answer the next QUESTION:
Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the company, Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year, news broke that a police sting operation had revealed a drug ring operating in the Providence, Rhode Island office in the United States. Video from the office's video surveillance cameras leaked to news operations showed a drug exchange between Special Handling staff and undercover officers.
In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that upper management believed had let the criminal elements conduct their illicit transactions. After a few weeks under Kelly's direction, the office became a model of efficiency and customer service. Kelly monitored his workers' activities using the same cameras that had recorded the illegal conduct of their former co-workers.
Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The company has received numerous reports of the staff leaving the office unattended. When Kelly arrived, he found that even when present, the staff often spent their days socializing or conducting personal business on their mobile phones. Again, he observed their behaviors using surveillance cameras. He issued written reprimands to six staff members based on the first day of video alone.
Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data Protection Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was told that the company's license for the cameras listed facility security as their main use, but he does not know why this matters. He has pointed out to his superiors that the company's training programs on privacy protection and data collection mention nothing about surveillance video.
You are a privacy protection consultant, hired by the company to assess this incident, report on the legal and compliance issues, and recommend next steps.
What does this example best illustrate about training requirements for privacy protection?

• A. Training must be repeated frequently to respond to new legislation.
• B. Training needs must be weighed against financial costs.
• C. Training on local laws must be implemented for all personnel.
• D. Training must include assessments to verify that the material is mastered.

Answer: C

Explanation:
This answer is the best way to illustrate the training requirements for privacy protection, as it shows the importance of understanding and complying with the different legal and regulatory frameworks that apply to the organization's data processing activities in different jurisdictions. Training on local laws must be implemented for all personnel who are involved in or responsible for collecting, using, disclosing, storing or transferring personal data across borders, as they may face different obligations and restrictions depending on the nature and location of the data and the data subjects. Training on local laws can help to prevent or mitigate the risks of violating the privacy rights of individuals, facing legal actions, fines, sanctions or investigations from authorities, or losing trust and reputation among customers, partners and stakeholders. References: IAPP CIPM Study Guide, page 901; ISO/IEC 27002:2013, section 7.2.2

NEW QUESTION # 163
What is the main purpose in notifying data subjects of a data breach?

• A. To avoid financial penalties and legal liability
• B. To ensure organizations have accountability for the sufficiency of their security measures
• C. To enable regulators to understand trends and developments that may shape the law
• D. To allow individuals to take any actions required to protect themselves from possible consequences

Answer: B

NEW QUESTION # 164
Which of the following actions is NOT required during a data privacy diligence process for Merger & Acquisition (M&A) deals?

• A. Update business processes to handle Data Subject Requests (DSRs).
• B. Revise inventory of applications that house personal data and data mapping.
• C. Compare the original use of personal data to post-merger use.
• D. Perform a privacy readiness assessment before the deal.

Answer: D

Explanation:
A privacy readiness assessment is not required during a data privacy diligence process for Merger & Acquisition (M&A) deals, as it is usually done before the deal to evaluate the privacy maturity and compliance level of the target organization. The other options are required during the data privacy diligence process to ensure that the personal data of both organizations are handled in accordance with the applicable laws and regulations, as well as the expectations of the data subjects and stakeholders. References: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 4: Manage data transfers.

NEW QUESTION # 165
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