IAPP CIPM Exam Questions

Question 6 of 240

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 Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.

What administrative safeguards should be implemented to protect the collected data while in use by Manasa and her product management team?

A.

Document the data flows for the collected data.

B.

Conduct a Privacy Impact Assessment (PIA) to evaluate the risks involved.

C.

Implement a policy restricting data access on a "need to know" basis.

D.

Limit data transfers to the US by keeping data collected in Europe within a local data center.

Correct Answer: C

Implementing a policy restricting data access on a 'need to know' basis is a critical administrative safeguard. It ensures that only those who require access to the data for their specific roles can view or use it. This is essential for protecting sensitive information, especially given the extensive access granted within the company through the Eureka program. By limiting access, the risk of data breaches or misuse is minimized, providing an effective layer of protection for the collected data while it is in use by the product management team.

Question 7 of 240

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 Eureka. 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 element of the Privacy by Design (PbD) framework might the Handy Helper violate?

A.

Failure to obtain opt-in consent to marketing.

B.

Failure to observe data localization requirements.

C.

Failure to implement the least privilege access standard.

D.

Failure to integrate privacy throughout the system development life cycle.

Correct Answer: D

The Handy Helper appears to violate the Privacy by Design (PbD) principle of integrating privacy throughout the system development life cycle. PbD mandates that privacy is considered and embedded from the earliest stages of design and continues through the development and deployment of the system. In this scenario, crucial privacy aspects were overlooked, such as obtaining proper consent for data usage, limiting access to sensitive data, and ensuring transparency about data handling practices. These omissions indicate that privacy considerations were not integrated into the system development life cycle.

Question 8 of 240

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 Eureka. 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 advise the distributor that Omnipresent Omnimedia has certified to the Privacy Shield Framework and there should be no issues.

B.

Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released.

C.

Sanjay should document the data life cycle of the data collected by the Handy Helper.

D.

Sanjay should write a privacy policy to include with the Handy Helper user guide.

Correct Answer: B

To minimize the risks of offering the product in Europe, Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released. This is because Europe has strict data protection regulations, such as the General Data Protection Regulation (GDPR), that require a thorough assessment of how personal data is collected, stored, and used. By ensuring compliance with these regulations prior to release, Sanjay can address potential privacy issues and prevent legal and reputational risks for Omnipresent Omnimedia.

Question 9 of 240

Which statement is FALSE regarding the use of technical security controls?

A.

Technical security controls are part of a data governance strategy.

B.

Technical security controls deployed for one jurisdiction often satisfy another jurisdiction.

C.

Most privacy legislation lists the types of technical security controls that must be implemented.

D.

A person with security knowledge should be involved with the deployment of technical security controls.

Correct Answer: C

Most privacy legislation typically does not specify the exact types of technical security controls that must be implemented. Instead, these laws and regulations generally outline broad requirements or principles for safeguarding data, leaving it up to organizations to determine the specific technical controls needed based on their unique circumstances and the nature of the data they are handling. Therefore, the statement saying that most privacy legislation lists the types of technical security controls that must be implemented is false.

Question 10 of 240

An organization's privacy officer was just notified by the benefits manager that she accidentally sent out the retirement enrollment report of all employees to a wrong vendor.

Which of the following actions should the privacy officer take first?

A.

Perform a risk of harm analysis.

B.

Report the incident to law enforcement.

C.

Contact the recipient to delete the email.

D.

Send firm-wide email notification to employees.

Correct Answer: C

The privacy officer should first contact the recipient to delete the email. The immediate priority is to mitigate any potential harm by containing the breach and ensuring that no further unauthorized access to the sensitive information occurs.