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The most effective way to support organizational privacy awareness objectives is D. Customizing awareness training by business unit function.

A comprehensive explanation is:

Organizational privacy awareness objectives are the goals and expectations that an organization sets for its employees and stakeholders regarding the protection and management of personal data. Privacy awareness objectives may vary depending on the nature, scope, and purpose of the organization’s data processing activities, as well as the legal, regulatory, contractual, and ethical obligations and implications that apply to them.

One of the best practices to support organizational privacy awareness objectives is to customize awareness training by business unit function. This means that the organization should design and deliver privacy awareness training programs that are tailored to the specific roles, responsibilities, and needs of each business unit or department within the organization. Customizing awareness training by business unit function can have several benefits, such as:

Enhancing the relevance and effectiveness of the training content and methods for each audience group, by addressing their specific privacy challenges, risks, and opportunities.

Increasing the engagement and motivation of the trainees, by showing them how privacy relates to their daily tasks, goals, and performance.

Improving the retention and application of the training knowledge and skills, by providing practical examples, scenarios, and exercises that reflect the real-world situations and problems that the trainees may encounter.

Fostering a culture of privacy across the organization, by creating a common language and understanding of privacy concepts, principles, and practices among different business units or departments.

Some examples of how to customize awareness training by business unit function are:

Providing different levels or modules of training based on the degree of access or exposure to personal data that each business unit or department has. For example, a basic level of training for all employees, an intermediate level of training for employees who handle personal data occasionally or incidentally, and an advanced level of training for employees who handle personal data regularly or extensively.

Providing different topics or themes of training based on the type or category of personal data that each business unit or department processes. For example, a general topic of training for employees who process non-sensitive or non-personal data, a specific topic of training for employees who process sensitive or special data categories (such as health, biometric, financial, or political data), and a specialized topic of training for employees who process high-risk or high-value data (such as intellectual property, trade secrets, or customer loyalty data).

Providing different formats or modes of training based on the preferences or constraints of each business unit or department. For example, a face-to-face format of training for employees who work in the same location or office, an online format of training for employees who work remotely or across different time zones, and a blended format of training for employees who work in a hybrid mode or have flexible schedules.

The other options are not as effective as option D.

Funding in-depth training and awareness education for data privacy staff (A) may improve the competence and confidence of the data privacy staff who are responsible for designing and implementing the privacy policies and practices of the organization, but it does not necessarily support the organizational privacy awareness objectives for the rest of the employees and stakeholders.

Implementing an annual training certification process (B) may ensure that the employees and stakeholders are updated and refreshed on the privacy policies and practices of the organization on a regular basis, but it does not necessarily address their specific privacy needs and challenges based on their business unit function.

Including mandatory awareness training as part of performance evaluations © may incentivize the employees and stakeholders to participate in and complete the privacy awareness training programs offered by the organization, but it does not necessarily enhance their understanding and application of privacy concepts and principles based on their business unit function.

The value proposition of a PIA is not understood by management is the greatest obstacle to conducting a PIA, as it may result in lack of support, funding, resources or commitment for the PIA process and outcomes. Management may not appreciate or recognize the benefits of a PIA, such as enhancing privacy protection, reducing privacy risks and costs, increasing customer trust and satisfaction, and complying with privacy laws and regulations. Management may also perceive a PIA as a burden, a delay or a hindrance to the system or project development and delivery. The other options are not as significant as the value proposition of a PIA is not understood by management as obstacles to conducting a PIA. Conducting a PIA requires significant funding and resources is an obstacle to conducting a PIA, but it may be overcome by demonstrating the return on investment or the cost-benefit analysis of a PIA. PIAs need to be performed many times in a year is an obstacle to conducting a PIA, but it may be mitigated by adopting a scalable or modular approach to PIAs that can be tailored to different types or levels of systems or projects. The organization lacks knowledge of PIA methodology is an obstacle to conducting a PIA, but it may be resolved by acquiring or developing the necessary skills, tools or guidance for performing PIAs1, p. 67-68 References: 1: CDPSE Review Manual (Digital Version)

The best practice to protect data privacy when disposing removable backup media is B. Data sanitization.

A comprehensive explanation is:

Data sanitization is the process of permanently and irreversibly erasing or destroying the data on a storage device or media, such as a hard drive, a USB drive, a CD/DVD, etc. Data sanitization ensures that the data cannot be recovered or reconstructed by any means, even by using specialized software or hardware tools. Data sanitization is also known as data wiping, data erasure, data destruction, or data disposal.

Data sanitization is the best practice to protect data privacy when disposing removable backup media because it prevents unauthorized access, disclosure, theft, or misuse of the sensitive or confidential data that may be stored on the media. Data sanitization also helps to comply with the legal and regulatory requirements and standards for data protection and privacy, such as the General Data Protection Regulation (GDPR), the Health Insurance Portability and Accountability Act (HIPAA), the Payment Card Industry Data Security Standard (PCI DSS), etc.

There are different methods and techniques for data sanitization, depending on the type and format of the storage device or media. Some of the common methods are:

Overwriting: Overwriting replaces the existing data on the device or media with random or meaningless data, such as zeros, ones, or patterns. Overwriting can be done multiple times to increase the level of security and assurance. Overwriting is suitable for magnetic media, such as hard disk drives (HDDs) or tapes.

Degaussing: Degaussing exposes the device or media to a strong magnetic field that disrupts and destroys the magnetic structure and alignment of the data. Degaussing renders the device or media unusable and unreadable. Degaussing is suitable for magnetic media, such as hard disk drives (HDDs) or tapes.

Physical Destruction: Physical destruction involves applying physical force or damage to the device or media that breaks it into small pieces or shreds it. Physical destruction can be done by using mechanical tools, such as shredders, crushers, drills, hammers, etc., or by using thermal methods, such as incineration, melting, etc. Physical destruction is suitable for any type of media, such as hard disk drives (HDDs), solid state drives (SSDs), USB drives, CDs/DVDs, etc.

Data encryption (A) is not a good practice to protect data privacy when disposing removable backup media because it does not erase or destroy the data on the media. Data encryption only transforms the data into an unreadable format that can only be accessed with a key or a password. However, if the key or password is lost, stolen, compromised, or guessed by an attacker, the data can still be decrypted and exposed. Data encryption is more suitable for protecting data in transit or at rest, but not for disposing data.

Data scrambling © is not a good practice to protect data privacy when disposing removable backup media because it does not erase or destroy the data on the media. Data scrambling only rearranges the order of the bits or bytes of the data to make it appear random or meaningless. However, if the algorithm or pattern of scrambling is known or discovered by an attacker, the data can still be unscrambled and restored. Data scrambling is more suitable for obfuscating data for testing or debugging purposes, but not for disposing data.

Data masking (D) is not a good practice to protect data privacy when disposing removable backup media because it does not erase or destroy the data on the media. Data masking only replaces some parts of the data with fictitious or anonymized values to hide its true identity or meaning. However, if the original data is still stored somewhere else or if the masking technique is weak or reversible by an attacker, the data can still be unmasked and revealed. Data masking is more suitable for protecting data in use or in analysis, but not for disposing data.

Storing tokens of PII directly in database fields undermines the security of tokenization and risks re-identification, making it the most concerning issue. Shared drives (A) and lack of labels (B) are governance gaps, and limited third-party access (C) can be controlled contractually, but token misuse (D) poses direct privacy risk.

“Improper token storage can compromise de-identification, reintroducing privacy risk.”

Privacy by design requires proactive, default, and continuous integration of privacy controls across the entire data life cycle (collection through disposal). Limiting to breach response (B) or remediation (C) is reactive, and focusing only on final product development (D) misses earlier phases where most risk originates.

“Embed privacy from the outset and across the full life cycle of processing activities.”

National data privacy legislative and regulatory requirements in each relevant jurisdiction are the most important data protection consideration for a global organization that is planning to implement a customer relationship management (CRM) system to be used in offices based in multiple countries, as they would determine the legal obligations and responsibilities of the organization with respect to the collection, use, disclosure and transfer of customer personal data across different jurisdictions. National data privacy legislative and regulatory requirements may vary significantly from country to country, depending on the type or nature of personal data or data processing activities, and may impose different rules and standards for obtaining consent, providing notice, ensuring security, enforcing rights, reporting breaches, appointing representatives or transferring data. The organization would need to comply with the national data privacy legislative and regulatory requirements in each relevant jurisdiction where it operates or where its customers are located, and to implement appropriate measures and safeguards to ensure compliance. The other options are not as important as national data privacy legislative and regulatory requirements in each relevant jurisdiction as data protection considerations for a global organization that is planning to implement a CRM system to be used in offices based in multiple countries. Industry best practice related to information security standards in each relevant jurisdiction may provide some guidance or benchmarks for ensuring security of customer personal data, but they may not reflect the specific context or needs of the organization or the customers, or comply with the legal obligations and responsibilities of the organization. Identity and access management mechanisms to restrict access based on need to know may help to protect customer personal data from unauthorized access, modification or disclosure by internal or external parties, but they may not address other aspects of data protection, such as consent, notice, rights, breaches, representatives or transfers. Encryption algorithms for securing customer personal data at rest and in transit may help to protect customer personal data from unauthorized access, modification or disclosure by internal or external parties, but they may not address other aspects of data protection, such as consent, notice, rights, breaches, representatives or transfers1, p. 63-64 References: 1: CDPSE Review Manual (Digital Version)

Data sanitization is a process of permanently erasing or destroying data from a storage device or media to prevent unauthorized access or recovery of the data. Data sanitization methods can include physical destruction, degaussing, overwriting, encryption or cryptographic erasure. The most important consideration when using advanced data sanitization methods to ensure privacy data will be unrecoverable is the type of media on which the data is stored, as different media types may require different methods or techniques to achieve effective sanitization. For example, physical destruction may be suitable for optical disks or tapes, but not for solid state drives (SSDs) or flash memory devices. Degaussing may be effective for magnetic disks or tapes, but not for optical disks or SSDs. Overwriting may work for hard disk drives (HDDs) or SSDs, but not for tapes or optical disks. Encryption or cryptographic erasure may be applicable for any media type, but may require additional security measures to protect the encryption keys or certificates. The other options are not as important as the type of media when using advanced data sanitization methods. Subject matter expertise may be helpful, but not essential, as long as the appropriate method is selected and applied correctly. Regulatory compliance requirements may influence the choice of method, but not necessarily determine it, as different methods may meet different standards or criteria. Location of data may affect the feasibility or cost of applying a method, but not its effectiveness or suitability., p. 93-94 References: : CDPSE Review Manual (Digital Version)

Sensitive personal data is a subset of personal data that reveals or relates to more intimate or confidential aspects of a person’s identity, such as their racial or ethnic origin, religious or philosophical beliefs, health status, sexual orientation, political opinions, trade union membership, biometric or genetic data, or criminal record. Sensitive personal data is subject to more stringent legal and regulatory protections and requires a higher level of consent from the data subject to be processed. Mailing address, bank account login ID, and contact phone number are examples of personal data, but not sensitive personal data, as they do not reveal or relate to such intimate or confidential aspects of a person’s identity.

Following an established privacy framework is the most important step when developing an organizational data privacy program because it provides a structured and consistent approach to identify, assess, and manage privacy risks and compliance obligations. A privacy framework can also help to align the privacy program with the organization’s strategic goals, values, and culture, as well as to communicate and demonstrate the privacy program’s effectiveness to internal and external stakeholders. Some examples of established privacy frameworks are the NIST Privacy Framework, the ISO/IEC 27701:2019, and the AICPA Privacy Maturity Model.

A privacy risk assessment is a process of identifying, analyzing and evaluating the privacy risks associated with the collection, use, disclosure or retention of personal data. A privacy risk assessment is the best way to distinguish between a privacy risk and compliance risk, as it would help to determine the likelihood and impact of privacy incidents or breaches that could affect the rights and interests of the data subjects, as well as the legal obligations and responsibilities of the organization. A privacy risk assessment would also help to identify and implement appropriate controls and measures to mitigate or reduce the privacy risks and ensure compliance with privacy principles, laws and regulations. The other options are not as effective as conducting a privacy risk assessment in distinguishing between a privacy risk and compliance risk. Performing a privacy risk audit is a process of verifying and validating the effectiveness and adequacy of the privacy controls and measures implemented by the organization, but it does not necessarily identify or evaluate the privacy risks or compliance risks. Validating a privacy risk attestation is a process of confirming and certifying the accuracy and completeness of the privacy information or statements provided by the organization, but it does not necessarily identify or evaluate the privacy risks or compliance risks. Conducting a privacy risk remediation exercise is a process of implementing corrective actions or improvements to address the identified or reported privacy risks or compliance risks, but it does not necessarily distinguish between them1, p. 66-67 References: 1: CDPSE Review Manual (Digital Version)