Pass the IAPP Certified Information Privacy Manager CIPM Questions and answers with CertsForce

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Questions # 1:

SCENARIO

Please use the following to answer the next QUESTION:

Martin Briseño is the director of human resources at the Canyon City location of the U.S. hotel chain Pacific Suites. In 1998, Briseño decided to change the hotel’s on-the-job mentoring model to a standardized training program for employees who were progressing from line positions into supervisory positions. He developed a curriculum comprising a series of lessons, scenarios, and assessments, which was delivered in-person to small groups. Interest in the training increased, leading Briseño to work with corporate HR specialists and software engineers to offer the program in an online format. The online program saved the cost of a trainer and allowed participants to work through the material at their own pace.

Upon hearing about the success of Briseño’s program, Pacific Suites corporate Vice President Maryanne Silva-Hayes expanded the training and offered it company-wide. Employees who completed the program received certification as a Pacific Suites Hospitality Supervisor. By 2001, the program had grown to provide industry-wide training. Personnel at hotels across the country could sign up and pay to take the course online. As the program became increasingly profitable, Pacific Suites developed an offshoot business, Pacific Hospitality Training (PHT). The sole focus of PHT was developing and marketing a variety of online courses and course progressions providing a number of professional certifications in the hospitality industry.

By setting up a user account with PHT, course participants could access an information library, sign up for courses, and take end-of-course certification tests. When a user opened a new account, all information was saved by default, including the user’s name, date of birth, contact information, credit card information, employer, and job title. The registration page offered an opt-out choice that users could click to not have their credit card numbers saved. Once a user name and password were established, users could return to check their course status, review and reprint their certifications, and sign up and pay for new courses. Between 2002 and 2008, PHT issued more than 700,000 professional certifications.

PHT’s profits declined in 2009 and 2010, the victim of industry downsizing and increased competition from e- learning providers. By 2011, Pacific Suites was out of the online certification business and PHT was dissolved. The training program’s systems and records remained in Pacific Suites’ digital archives, un-accessed and unused. Briseño and Silva-Hayes moved on to work for other companies, and there was no plan for handling the archived data after the program ended. After PHT was dissolved, Pacific Suites executives turned their attention to crucial day-to-day operations. They planned to deal with the PHT materials once resources allowed.

In 2012, the Pacific Suites computer network was hacked. Malware installed on the online reservation system exposed the credit card information of hundreds of hotel guests. While targeting the financial data on the reservation site, hackers also discovered the archived training course data and registration accounts of Pacific Hospitality Training’s customers. The result of the hack was the exfiltration of the credit card numbers of recent hotel guests and the exfiltration of the PHT database with all its contents.

A Pacific Suites systems analyst discovered the information security breach in a routine scan of activity reports. Pacific Suites quickly notified credit card companies and recent hotel guests of the breach, attempting to prevent serious harm. Technical security engineers faced a challenge in dealing with the PHT data.

PHT course administrators and the IT engineers did not have a system for tracking, cataloguing, and storing information. Pacific Suites has procedures in place for data access and storage, but those procedures were not implemented when PHT was formed. When the PHT database was acquired by Pacific Suites, it had no owner or oversight. By the time technical security engineers determined what private information was compromised, at least 8,000 credit card holders were potential victims of fraudulent activity.

What key mistake set the company up to be vulnerable to a security breach?

Options:

A.

Collecting too much information and keeping it for too long


B.

Overlooking the need to organize and categorize data


C.

Failing to outsource training and data management to professionals


D.

Neglecting to make a backup copy of archived electronic files


Expert Solution
Questions # 2:

SCENARIO

Please use the following to answer the next QUESTION:

Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the

practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.

Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal data. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.

Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following day, to get insight into how the office computer system is currently set-up and managed.

Richard needs to closely monitor the vendor in charge of creating the firm's database mainly because of what?

Options:

A.

The vendor will be required to report any privacy violations to the appropriate authorities.


B.

The vendor may not be aware of the privacy implications involved in the project.


C.

The vendor may not be forthcoming about the vulnerabilities of the database.


D.

The vendor will be in direct contact with all of the law firm's personal data.


Expert Solution
Questions # 3:

In privacy protection, what is a "covered entity"?

Options:

A.

Personal data collected by a privacy organization.


B.

An organization subject to the privacy provisions of HIPAA.


C.

A privacy office or team fully responsible for protecting personal information.


D.

Hidden gaps in privacy protection that may go unnoticed without expert analysis.


Expert Solution
Questions # 4:

What is the main purpose in notifying data subjects of a data breach?

Options:

A.

To avoid financial penalties and legal liability.


B.

To enable regulators to understand trends and developments that may shape the law.


C.

To ensure organizations have accountability for the sufficiency of their security measures.


D.

To allow individuals to take any actions required to protect themselves from possible consequences.


Expert Solution
Questions # 5:

An organization is establishing a mission statement for its privacy program. Which of the following statements would be the best to use?

Options:

A.

This privacy program encourages cross-organizational collaboration which will stop all data breaches


B.

Our organization was founded in 2054 to reduce the chance of a future disaster like the one that occurred ten years ago. All individuals from our area of the country should be concerned about a future disaster. However, with our privacy program, they should not be concerned about the misuse of their information.


C.

The goal of the privacy program is to protect the privacy of all individuals who support our organization. To meet this goal, we must work to comply with all applicable privacy laws.


D.

In the next 20 years, our privacy program should be able to eliminate 80% of our current breaches. To do this, everyone in our organization must complete our annual privacy training course and all personally identifiable information must be inventoried.


Expert Solution
Questions # 6:

Which of the following controls does the PCI DSS framework NOT require?

Options:

A.

Implement strong asset control protocols.


B.

Implement strong access control measures.


C.

Maintain an information security policy.


D.

Maintain a vulnerability management program.


Expert Solution
Questions # 7:

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?

Options:

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


Expert Solution
Questions # 8:

Which of the following is NOT a main technical data control area?

Options:

A.

Obfuscation.


B.

Tokenization.


C.

Access controls.


D.

Data minimization.


Expert Solution
Questions # 9:

In which situation would a Privacy Impact Assessment (PIA) be the least likely to be required?

Options:

A.

If a company created a credit-scoring platform five years ago.


B.

If a health-care professional or lawyer processed personal data from a patient's file.


C.

If a social media company created a new product compiling personal data to generate user profiles.


D.

If an after-school club processed children's data to determine which children might have food allergies.


Expert Solution
Questions # 10:

While trying to e-mail her manager, an employee has e-mailed a list of all the company's customers, including their bank details, to an employee with the same name at a different company. Which of the following would be the first stage in the incident response plan under the General Data Protection Regulation (GDPR)?

Options:

A.

Notification to data subjects.


B.

Containment of impact of breach.


C.

Remediation offers to data subjects.


D.

Notification to the Information Commissioner's Office (ICO).


Expert Solution
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