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IAPP CIPM Certification is an essential credential for professionals who handle privacy-related matters in an organization. Certified Information Privacy Manager (CIPM) certification demonstrates that the individual has a thorough understanding of privacy program management and can effectively manage and implement privacy policies and procedures. Certified Information Privacy Manager (CIPM) certification is highly valued in the industry and can enhance an individual's career opportunities and earning potential.
IAPP Certified Information Privacy Manager (CIPM) Sample Questions (Q223-Q228):
NEW QUESTION # 223
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 process personal information in a manner compatible with its original purpose
- B. 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
- C. Failure to provide the means for a data subject to rectify inaccuracies in personal data
- D. Failure to implement technical and organizational measures to ensure data protection is enshrined by design and default
Answer: D
Explanation:
Explanation
The GDPR specifies fines that may be levied against data controllers for certain infringements. According to Article 83(4)(a) of the GDPR, failure to implement technical and organizational measures to ensure data protection is enshrined by design and default 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, whichever is higher. Data protection by design and default is a principle that requires data controllers to integrate data protection considerations into every stage of the processing activities, from the conception to the execution, and to adopt appropriate measures to safeguard the rights and interests of the data subjects by default, such as minimizing the amount and retention period of personal data, pseudonymizing or encrypting personal data, ensuring transparency and accountability, and enabling data subject rights.
References:
* CIPM Body of Knowledge (2021), Domain I: Privacy Program Governance, Section A: Privacy Governance Models, Subsection 2: Privacy by Design
* CIPM Study Guide (2021), Chapter 2: Privacy Governance Models, Section 2.2: Privacy by Design
* CIPM Textbook (2019), Chapter 2: Privacy Governance Models, Section 2.2: Privacy by Design
* CIPM Practice Exam (2021), Question 130
* GDPR Article 83(4)(a) and Article 25
NEW QUESTION # 224
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.
In terms of compliance with regulatory and legislative changes, Anton has a misconception regarding?
- A. The method of recordkeeping.
- B. The type of required qualifications.
- C. The timeline for monitoring.
- D. The use of internal employees.
Answer: C
Explanation:
In terms of compliance with regulatory and legislative changes, Anton has a misconception regarding the timeline for monitoring. He believes that the company should be safe for another five years after conducting a compliance assessment and documenting the analysis. However, this is a risky and unrealistic assumption that could expose the company to legal liabilities and penalties. Regulatory and legislative changes are dynamic and frequent in today's business environment. They can affect various aspects of the company's operations, such as data protection, online marketing, consumer rights, labor laws, tax laws, environmental laws, etc5 Therefore, the company needs to monitor these changes continuously and proactively to ensure compliance at all times. Waiting for five years to check for compliance again could result in missing important updates or requirements that could impact the company's business practices or obligations. Moreover, compliance monitoring is not only a one-time activity but an ongoing process that involves evaluating the effectiveness of the company's policies and procedures in meeting the regulatory standards and expectations6 Compliance monitoring also helps to identify any gaps or weaknesses in the company's compliance program and take corrective actions to improve it. Therefore, Anton should revise his timeline for monitoring regulatory and legislative changes and adopt a more regular and systematic approach that aligns with the company's risk profile and regulatory environment. References: 5: Regulatory Change Management: How To Keep Up With Regulatory Changes; 6: Compliance Monitoring - What Is It?
NEW QUESTION # 225
How do privacy audits differ from privacy assessments?
- A. They are evidence-based.
- B. They are based on standards.
- C. They are non-binding.
- D. They are conducted by external parties.
Answer: B
NEW QUESTION # 226
Data retention and destruction policies should meet all of the following requirements EXCEPT?
- A. Personal information should be retained only for as long as necessary to perform its stated purpose.
- B. Data destruction triggers and methods should be documented.
- C. The organization should be documenting and reviewing policies of its other functions to ensure alignment (e.g. HR, business development, finance, etc.).
- D. Documentation related to audit controls (third-party or internal) should be saved in a non-permanent format by default.
Answer: D
Explanation:
Explanation
Documentation related to audit controls (third-party or internal) should be saved in a permanent format by default, not a non-permanent one. This is to ensure that the organization can demonstrate its compliance with the applicable laws and regulations, as well as its own policies and procedures, in case of an audit or a legal challenge. The other options are valid requirements for data retention and destruction policies, as they help to minimize the risks and costs associated with storing personal information beyond its intended purpose. References: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task
3: Manage data retention and disposal.
NEW QUESTION # 227
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 practice would afford the Director the most rigorous way to check on the program's compliance with laws, regulations and industry best practices?
- A. Assessment.
- B. Auditing.
- C. Forensics.
- D. Monitoring.
Answer: B
Explanation:
Explanation
This is the most rigorous way to check on the program's compliance with laws, regulations and industry best practices, as it involves an independent and objective examination of the program's records, activities and performance against established criteria.
NEW QUESTION # 228
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