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Height, weight, and activities are the most legitimate information to collect for business reasons in this situation, as they are directly related to the purpose and functionality of a wellness smartwatch application that aims to monitor and improve the health and fitness of its users. Collecting height, weight, and activities would also comply with the data minimization principle that requires limiting the collection, storage and processing of personal data to what is necessary and relevant for the intended purposes. The other options are not legitimate information to collect for business reasons in this situation, as they are not related to the purpose and functionality of a wellness smartwatch application and may violate the privacy rights and preferences of its users. Collecting sleep schedule and calorie intake may be useful for some users who want to track their sleep quality and nutrition intake, but they are not essential for a wellness smartwatch application and may require additional consent or justification from the users. Collecting education and profession may be irrelevant for a wellness smartwatch application and may be used for other purposes, such as marketing or profiling, without the consent or knowledge of the users. Collecting race, age, and gender may be sensitive for some users who do not want to disclose their personal characteristics or identity, and may require additional safeguards or measures to protect their privacy1, p. 75-76 References: 1: CDPSE Review Manual (Digital Version)

Software hardening is a technique that mitigates design flaws in the application development process that may contribute to potential leakage of personal data. Software hardening is a process of modifying or configuring software to make it more secure and resilient against attacks or exploitation. Software hardening can involve various methods, such as removing unnecessary features or functions, disabling debugging or testing modes, applying patches or updates, implementing secure coding practices, etc. Software hardening helps to protect personal data by preventing or reducing the vulnerabilities that can allow unauthorized access, use, disclosure, or transfer of personal data. References: : CDPSE Review Manual (Digital Version), page 151

Validating the privacy framework is a responsibility of the audit function in helping an organization address privacy compliance requirements, as it would help to verify and validate the effectiveness and adequacy of the privacy framework implemented by the organization to comply with privacy principles, laws and regulations. Validating the privacy framework would also help to identify and report any gaps, weaknesses or issues in the privacy framework, and to provide recommendations for improvement or remediation. The other options are not responsibilities of the audit function in helping an organization address privacy compliance requirements. Approving privacy impact assessments (PIAs) is a responsibility of management or governance function in helping an organization address privacy compliance requirements, as they would have authority and accountability for approving PIAs conducted by project teams or business units before implementing any system, project, program or initiative that involves personal data processing activities. Managing privacy notices provided to customers is a responsibility of operational function in helping an organization address privacy compliance requirements, as they would have direct contact and interaction with customers and would be responsible for providing clear and accurate information about how their personal data is collected, used, disclosed and transferred by the organization. 

According to the General Data Protection Regulation (GDPR), data subjects have the right to withdraw their consent for processing their personal data at any time. However, this right does not apply when the processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, in accordance with Article 89(1) of the GDPR1.

References: 1: Article 7(3) and Article 89(1) of the GDPR

To ensure the protection of personal data, privacy policies should mandate that access to information system applications be authorized by the business application owner, because they are the ones who are responsible for defining the business requirements, functions, and objectives of the applications. The business application owner can also determine the appropriate level of access for different users or groups based on their roles, responsibilities, and needs. The business application owner can also monitor and review the access control policies and procedures to ensure that they are effective and compliant with the privacy regulations and standards.

References:

Access Control Policy and Implementation Guides, CSRC

What is Authorization and Access Control?, ICANN

An audit log is a record of the activities and events that occur in an information system, such as an application hosting personal data. An audit log can help to monitor, detect, investigate and prevent unauthorized or malicious access, use, modification or deletion of personal data. An audit log can also help to demonstrate compliance with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA). An audit log should capture the following information for each event: 9

The date and time of the event

The identity of the user or system that performed the event

The type and description of the event

The outcome or result of the event

The personal data that were accessed, used, modified or deleted

The last user who accessed personal data is the most important information to capture in the audit log, as it can help to identify who is responsible for any data breach or misuse of personal data. It can also help to verify that only authorized and legitimate users have access to personal data, and that they follow the data use policy and the principle of least privilege. The last user who accessed personal data can also help to support data subjects’ rights, such as the right to access, rectify, erase or restrict their personal data.

The other options are less important or irrelevant to capture in the audit log of an application hosting personal data. Server details of the hosting environment are not related to personal data, and they can be obtained from other sources, such as network logs or configuration files. Last logins of privileged users are important to capture in a separate audit log for user account management, but they do not indicate what personal data were accessed or used by those users. Application error events are important to capture in a separate audit log for system performance and reliability, but they do not indicate what personal data were affected by those errors.

References:

IS Audit Basics: Auditing Data Privacy, section 4: “Audit logs should be maintained for all systems that process PII.”

Data Protection Audit Manual, section 3.2: “Audit trails should be kept for all processing operations involving personal data.”

Audit Logging Best Practices, section 2: “An audit log entry should contain enough information to answer who did what and when.”

A virtual private network (VPN) is a technology that creates a secure and encrypted connection over a public network, such as the internet. A VPN should be established first before authorizing remote access to a data store containing personal data, as it protects the data from unauthorized interception, modification, or disclosure by third parties. A VPN also helps to ensure the identity and authenticity of the remote users and devices accessing the data store. References: 2 Domain 2, Task 8

Attribute-based access control (ABAC) is the best approach for limiting the access of regional HR team members to employee data only within their regional office, because it allows for fine-grained and dynamic access control based on attributes of the subject, object, environment, and action. Attributes are characteristics or properties that can be used to describe or identify entities, such as users, resources, locations, roles, or permissions. ABAC uses policies and rules that evaluate the attributes and grant or deny access accordingly. For example, an ABAC policy could state that a user can access an employee record if and only if the user’s role is HR and the user’s region matches the employee’s region. This way, the access control can be tailored to the specific needs and context of the organization, without relying on predefined or fixed access levels.

References:

Attribute-Based Access Control (ABAC), NIST

What is Attribute-Based Access Control (ABAC)?, Axiomatics

Access Control Models – Westoahu Cybersecurity, Westoahu Cybersecurity

The primary reason for an organization to use hash functions when hardening application systems involved in biometric data processing is to reduce the risk of sensitive data breaches, because hash functions are one-way mathematical functions that transform biometric data into a unique and irreversible representation that cannot be reconstructed or reversed. This means that even if an attacker gains access to the hashed biometric data, they cannot use it to identify or impersonate the individual. Hash functions also help preserve the privacy and confidentiality of biometric data by preventing unauthorized access, modification, or disclosure.

References:

CDPSE Exam Content Outline, Domain 2 – Privacy Architecture (Privacy Architecture Implementation), Task 2: Implement privacy solutions1.

CDPSE Review Manual, Chapter 2 – Privacy Architecture, Section 2.3 – Privacy Architecture Implementation2.

CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 2 – Privacy Architecture, Section 2.4 – Remote Access3.