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QUESTION 1
What is a key feature of the privacy metric template adapted from the National Institute of Standards and Technology
(NIST)?
A. It provides suggestions about how to collect and measure data.
B. It can be tailored to an organization\\’s particular needs.
C. It is updated annually to reflect changes in government policy.
D. It is focused on organizations that do business internationally.
Correct Answer: A
QUESTION 2
SCENARIO
Please use the following to answer the next question:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner,
Anton, has found some degree of disorganization after touring the company headquarters. His uncle Henry
had always focused on production – not data processing – and Anton is concerned. In several storage
rooms, he has found paper files, disks, and old computers that appear to contain the personal data of
current and former employees and customers. Anton knows that a single break-in could irrevocably
damage the company\\’s relationship with its loyal customers. He intends to set a goal of guaranteed zero
loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of
the company. However, Kenneth – his uncle\\’s vice president and longtime confidante – wants to hold off
on Anton\\’s idea in favor of converting any paper records held at the company to electronic storage.
Kenneth believes this process would only take one or two years. Anton likes this idea; he envisions a
password-protected system that only he and Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier,
but it will simplify the management of the stored data. The heads of subsidiaries like the art gallery and
kitchenware store down the street will be responsible for their own information management. Then, any
unneeded subsidiary data still in Anton\\’s possession can be destroyed within the next few years.
After learning of a recent security incident, Anton realizes that another crucial step will be notifying
customers. Kenneth insists that two lost hard drives in question are not cause for concern; all of the data
was encrypted and not sensitive in nature. Anton does not want to take any chances, however. He intends
on sending notice letters to all employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related to
privacy protection. Kenneth oversaw the development of the company\\’s online presence about ten years
ago, but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning
another trusted employee with a law background the task of the compliance assessment. After a thorough
analysis, Anton knows the company should be safe for another five years, at which time he can order
another check. Documentation of this analysis will show auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the
effort is worth it. Anton wants his uncle\\’s legacy to continue for many years to come.
What would the company\\’s legal team most likely recommend to Anton regarding his planned
communication with customers?
A. To send consistent communication.
B. To shift to electronic communication.
C. To delay communications until local authorities are informed.
D. To consider under what circumstances communication is necessary.
Correct Answer: D
QUESTION 3
SCENARIO
Please use the following to answer the next question:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new
privacy officer. The company is based in California but thanks to some great publicity from a social media
influencer last year, the company has received an influx of sales from the EU and has set up a regional
office in Ireland to support this expansion. To become familiar with Ace Space\\’s practices and assess what
her privacy priorities will be, Penny has set up meetings with a number of colleagues to hear about the
work that they have been doing and their compliance efforts.
Penny\\’s colleague in Marketing is excited by the new sales and the company\\’s plans, but is also
concerned that Penny may curtail some of the growth opportunities he has planned. He tells her “I heard
someone in the breakroom talking about some new privacy laws but I really don\\’t think it affects us. We\\’re
just a small company. I mean we just sell accessories online, so what\\’s the real risk?” He has also told her
that he works with a number of small companies that help him get projects completed in a hurry. “We\\’ve
got to meet our deadlines otherwise we lose money. I just sign the contracts and get Jim in finance to push
through the payment. Reviewing the contracts takes time that we just don\\’t have.”
In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken a
number of precautions to protect its website from malicious activity, it has not taken the same level of care
of its physical files or internal infrastructure. Penny\\’s colleague in IT has told her that a former employee
lost an encrypted USB key with financial data on it when he left. The company nearly lost access to their
customer database last year after they fell victim to a phishing attack. Penny is told by her IT colleague that the IT team
“didn\\’t know what to do or who should do what. We hadn\\’t been trained on it but we\\’re a small team though, so it
worked out OK in the end.” Penny is concerned that these issues will compromise Ace Space\\’s privacy and data
protection.
Penny is aware that the company has solid plans to grow its international sales and will be working closely with the CEO
to give the organization a data “shake up”. Her mission is to cultivate a strong privacy culture within the company.
Penny has a meeting with Ace Space\\’s CEO today and has been asked to give her first impressions and an overview
of her next steps.
To establish the current baseline of Ace Space\\’s privacy maturity, Penny should consider all of the following factors
EXCEPT?
A. Ace Space\\’s documented procedures
B. Ace Space\\’s employee training program
C. Ace Space\\’s vendor engagement protocols
D. Ace Space\\’s content sharing practices on social media
Correct Answer: A
QUESTION 4
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.
Which is the best way to ensure that data on personal equipment is protected?
A. User risk training.
B. Biometric security.
C. Encryption of the data.
D. Frequent data backups.
Correct Answer: A
QUESTION 5
SCENARIO
Please use the following to answer the next question:
Edufox has hosted an annual convention of users of its famous e-learning software platform, and over
time, it has become a grand event. It fills one of the large downtown conference hotels and overflows into
the others, with several thousand attendees enjoying three days of presentations, panel discussions and
networking. The convention is the centerpiece of the company\\’s product rollout schedule and a great
training opportunity for current users. The sales force also encourages prospective clients to attend to get
a better sense of the ways in which the system can be customized to meet diverse needs and understand
that when they buy into this system, they are joining a community that feels like family.
This year\\’s conference is only three weeks away, and you have just heard news of a new initiative
supporting it: a smartphone app for attendees. The app will support late registration, highlight the featured
presentations and provide a mobile version of the conference program. It also links to a restaurant
reservation system with the best cuisine in the areas featured. “It\\’s going to be great,” the developer,
Deidre Hoffman, tells you, “if, that is, we actually get it working!” She laughs nervously but explains that
because of the tight time frame she\\’d been given to build the app, she outsourced the job to a local firm.
“It\\’s just three young people,” she says, “but they do great work.” She describes some of the other apps
they have built. When asked how they were selected for this job, Deidre shrugs. “They do good work, so I
chose them.”
Deidre is a terrific employee with a strong track record. That\\’s why she\\’s been charged to deliver this
rushed project. You\\’re sure she has the best interests of the company at heart, and you don\\’t doubt that
she\\’s under pressure to meet a deadline that cannot be pushed back. However, you have concerns about
the app\\’s handling of personal data and its security safeguards. Over lunch in the break room, you start to
talk to her about it, but she quickly tries to reassure you, “I\\’m sure with your help we can fix any security
issues if we have to, but I doubt there\\’ll be any. These people build apps for a living, and they know what
they\\’re doing. You worry too much, but that\\’s why you\\’re so good at your job!”
You see evidence that company employees routinely circumvent the privacy officer in developing new
initiatives.
How can you best draw attention to the scope of this problem?
A. Insist upon one-on-one consultation with each person who works around the privacy officer.
B. Develop a metric showing the number of initiatives launched without consultation and include it in reports,
presentations, and consultation.
C. Hold discussions with the department head of anyone who fails to consult with the privacy officer.
D. Take your concerns straight to the Chief Executive Officer.
Correct Answer: C
QUESTION 6
The General Data Protection Regulation (GDPR) specifies fines that may be levied against data controllers for certain
infringements. Which of the following will be subject to administrative fines of up to 10 000 000 EUR, or in the case of an
undertaking, up to 2% of the total worldwide annual turnover of the preceding financial year?
A. Failure to demonstrate that consent was given by the data subject to the processing of their personal data where it is used as the basis for processing
B. Failure to implement technical and organizational measures to ensure data protection is enshrined by design and
default
C. Failure to process personal information in a manner compatible with its original purpose
D. Failure to provide the means for a data subject to rectify inaccuracies in personal data
Correct Answer: A
QUESTION 7
What is the best way to understand the location, use and importance of personal data within an organization?
A. By analyzing the data inventory.
B. By testing the security of data systems.
C. By evaluating methods for collecting data.
D. By interviewing employees tasked with data entry.
Correct Answer: C
QUESTION 8
An executive for a multinational online retail company in the United States is looking for guidance in developing her
company\\’s privacy program beyond what is specifically required by law.
What would be the most effective resource for the executive to consult?
A. Internal auditors.
B. Industry frameworks.
C. Oversight organizations.
D. Breach notifications from competitors.
Correct Answer: B
QUESTION 9
In regards to the collection of personal data conducted by an organization, what must the data subject be allowed to
do?
A. Evaluate the qualifications of a third-party processor before any data is transferred to that processor.
B. Obtain a guarantee of prompt notification in instances involving unauthorized access of the data.
C. Set a time-limit as to how long the personal data may be stored by the organization.
D. Challenge the authenticity of the personal data and have it corrected if needed.
Correct Answer: C
QUESTION 10
An organization\\’s business continuity plan or disaster recovery plan does NOT typically include what?
A. Recovery time objectives.
B. Emergency response guidelines.
C. Statement of organizational responsibilities.
D. Retention schedule for storage and destruction of information.
Correct Answer: D
QUESTION 11
A Human Resources director at a company reported that a laptop containing employee payroll data was lost on the
train. Which action should the company take IMMEDIATELY?
A. Report the theft to law enforcement
B. Wipe the hard drive remotely
C. Report the theft to the senior management
D. Perform a multi-factor risk analysis
Correct Answer: D
QUESTION 12
SCENARIO
Please use the following to answer the next question:
Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with
her long-time business partner Sadie, Amira has watched the company grow into a major competitor in the
green energy market. The current line of products includes wind turbines, solar energy panels, and
equipment for geothermal systems. A talented team of developers means that NatGen\\’s line of products
will only continue to grow.
With the expansion, Amira and Sadie have received advice from new senior staff members brought on to
help manage the company\\’s growth. One recent suggestion has been to combine the legal and security
functions of the company to ensure observance of privacy laws and the company\\’s own privacy policy.
This sounds overly complicated to Amira, who wants departments to be able to use, collect, store, and
dispose of customer data in ways that will best suit their needs.
She does not want administrative oversight and complex structuring to get in the way of people doing
innovative work.
Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is
an unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen
will use the best possible equipment for electronic storage of customer and employee data. She simply
needs a list of equipment and an estimate of its cost. But the CIO insists that many issues are necessary
to consider before the company gets to that stage.
Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust
the monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these
managers can adjust the company privacy policy according to what works best for their particular
departments. NatGen\\’s CEOs know that flexible interpretations of the privacy policy in the name of
promoting green energy would be highly unlikely to raise any concerns with their customer base, as long
as the data is always used in course of normal business activities.
Perhaps what has been most perplexing to Sadie and Amira has been the CIO\\’s recommendation to
institute a privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by
allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy because
the employees need no special preparation. They will simply have to document any concerns they hear.
Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate culture
strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a unique
approach.
Based on the scenario, what additional change will increase the effectiveness of the privacy compliance hotline?
A. Outsourcing the hotline.
B. A system for staff education.
C. Strict communication channels.
D. An ethics complaint department.
Correct Answer: B
QUESTION 13
Which of the following is TRUE about a PIA (Privacy Impact Analysis)?
A. Any project that involves the use of personal data requires a PIA
B. A Data Protection Impact Analysis (DPIA) process includes a PIA
C. The PIA must be conducted at the early stages of the project lifecycle
D. The results from a previous information audit can be leveraged in a PIA process
Correct Answer: A
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