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The questions for CIPM were last updated on Oct 2, 2024.
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When conducting due diligence during an acquisition, what should a privacy professional avoid?
When conducting due diligence during an acquisition, a privacy professional should avoid allowing legal in both companies to handle the privacy laws and compliance. This is because privacy is not only a legal issue, but also a business, technical, and operational issue that requires cross-functional collaboration and expertise. A privacy professional should be involved in the due diligence process to assess the privacy risks and opportunities of the acquisition, such as the type and scope of data processing, the data protection policies and practices, the data transfer mechanisms and agreements, the data breach history and response plans, and the impacts on the data processing operations post-acquisition. A privacy professional should also benchmark the two companies' privacy policies against one another to identify any gaps or inconsistencies that need to be addressed before or after the acquisition, .Reference:[CIPM - International Association of Privacy Professionals], [Free CIPM Study Guide - International Association of Privacy Professionals]
An online retailer detects an incident involving customer shopping history but no keys have been compromised. The Privacy Offce is most concerned when it also involves?
An online retailer detects an incident involving customer shopping history but no keys have been compromised. The Privacy Office is most concerned when it also involves plain text personal identifiers. Plain text personal identifiers are data elements that can directly identify an individual, such as name, email address, phone number, or social security number. Plain text means that the data is not encrypted or otherwise protected from unauthorized access or disclosure. If an incident involves plain text personal identifiers, it poses a high risk to the privacy and security of the customers, as their personal data could be exposed, stolen, misused, or manipulated by malicious actors. The Privacy Office should take immediate steps to contain, assess, notify, evaluate, and prevent such incidents, .Reference:[CIPM - International Association of Privacy Professionals], [Free CIPM Study Guide - International Association of Privacy Professionals]
Your marketing team wants to know why they need a check box for their SMS opt-in. You explain it is part of the consumer's right to?
The marketing team needs a check box for their SMS opt-in because it is part of the consumer's right to be informed. This right means that consumers have the right to know how their personal data is collected, used, shared, and protected by the organization. The check box allows consumers to give their consent and opt-in to receive SMS messages from the organization, and also informs them of the purpose and scope of such messages. The other rights are not relevant in this case, as they are related to other aspects of data processing, such as correction, complaints, and access.Reference:CIPM Body of Knowledge, Domain IV: Privacy Program Communication, Section A: Communicating to Stakeholders, Subsection 1: Consumer Rights.
When conducting due diligence during an acquisition, what should a privacy professional avoid?
When conducting due diligence during an acquisition, a privacy professional should avoid allowing legal in both companies to handle the privacy laws and compliance. This is because legal teams may not have the expertise or the resources to address all the privacy issues and risks that may arise from the acquisition. A privacy professional should be involved in the due diligence process to ensure that the privacy policies, practices, and obligations of both companies are aligned and compliant with the applicable laws and regulations. The other options are not things that a privacy professional should avoid, but rather things that they should do as part of the due diligence process.Reference:CIPM Body of Knowledge, Domain V: Privacy Program Management, Section A: Privacy Program Administration, Subsection 3: Due Diligence.
SCENARIO
Please use the following to answer the next question
You were recently hired by InStyte Date Corp as a privacy manager to help InStyle Data Corp become compliant with a new data protection law
The law mandates that businesses have reasonable and appropriate security measures in place to protect personal data. Violations of that mandate are heavily fined and the legislators have stated that they will aggressively pursue companies that don t comply with the new law
You are paved with a security manager and tasked with reviewing InStyle Data Corp s current state and advising the business how it can meet the "reasonable and appropriate security" requirement InStyle Data Corp has grown rapidly and has not kept a data inventory or completed a data mapping InStyte Data Corp has also developed security-related policies ad hoc and many have never been implemented The various teams involved in the creation and testing of InStyle Data Corp s products experience significant turnover and do not have well defined roles There's little documentation addressing what personal data is processed by which product and for what purpose
Work needs to begin on this project immediately so that InStyle Data Corp can become compliant by the time the law goes into effect. You and you partner discover that InStyle Data Corp regularly sends files containing sensitive personal data back to its customers through email sometimes using InStyle Data Corp employees personal email accounts. You also team that InStyle Data Corp s privacy and information security teams are not informed of new personal data flows, new products developed by InStyte Data Corp that process personal data, or updates to existing InStyle Data Corp products that may change what or how the personal data is processed until after the product or update has gone have.
Through a review of InStyle Date Corp's test and development environment logs, you discover InStyle Data Corp sometimes gives login credentials to any InStyle Data Corp employee or contractor who requests them. The test environment only contains dummy data but the development environment contains personal data including Social Security Numbers, hearth ^formation and financial information All credentialed InStyle Data Corp employees and contractors have the ability to after and delete personal data in both environments regardless of their role or what project they are working on.
You and your partner provide a gap assessment citing the issues you spotted, along with recommended remedial actions and a method to measure implementation InStyle Data Corp implements all of the recommended security controls You review the processes roles, controls and measures taken to appropriately protect the personal data at every stop However, you realize there is no plan for monitoring and nothing in place addressing sanctions for violations of the updated policies and procedures InStyle Data Corp pushes back, stating they do not have the resources for such monitoring.
What aspect of the data management life cycle will still be unaddressed it you cannot find the resources to become compliant?
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