SCENARIO
Please use the following to answer the next question:
Chuck, a compliance auditor for a consulting firm focusing on healthcare clients, was required to travel to the client's office to perform an onsite review of the client's operations. He rented a car from Finley Motors upon arrival at the airport as so he could commute to and from the client's office. The car rental agreement was electronically signed by Chuck and included his name, address, driver's license, make/model of the car, billing rate, and additional details describing the rental transaction. On the second night, Chuck was caught by a red light camera not stopping at an intersection on his way to dinner. Chuck returned the car back to the car rental agency at the end week without mentioning the infraction and Finley Motors emailed a copy of the final receipt to the address on file.
Local law enforcement later reviewed the red light camera footage. As Finley Motors is the registered owner of the car, a notice was sent to them indicating the infraction and fine incurred. This notice included the license plate number, occurrence date and time, a photograph of the driver, and a web portal link to a video clip of the violation for further review. Finley Motors, however, was not responsible for the violation as they were not driving the car at the time and transferred the incident to AMP Payment Resources for further review. AMP Payment Resources identified Chuck as the driver based on the rental agreement he signed when picking up the car and then contacted Chuck directly through a written letter regarding the infraction to collect the fine.
After reviewing the incident through the AMP Payment Resources' web portal, Chuck paid the fine using his personal credit card. Two weeks later, Finley Motors sent Chuck an email promotion offering 10% off a future rental.
What should Finley Motors have done to incorporate the transparency principle of Privacy by Design (PbD)?
SCENARIO - Please use the following to answer the next question:
Wesley Energy has finally made its move, acquiring the venerable oil and gas exploration firm Lancelot from its long-time owner David Wilson. As a member of the transition team, you have come to realize that Wilson s quirky nature affected even Lancelot s data practices, which are maddeningly inconsistent. "The old man hired and fired IT people like he was changing his necktie,'1 one of Wilson s seasoned lieutenants tells you, as you identify the traces of initiatives left half complete.
For instance, while some proprietary data and personal information on clients and employees is encrypted, other sensitive^ information, including health information from surveillance testing of employees for toxic exposures, remains unencrypted, particularly when included within longer records with less-sensitive data.
You also find that data is scattered across applications, servers and facilities in a manner that at first glance seems almost random.
Among your preliminary findings of the condition of data at Lancelot are the following:
Cloud technology is supplied by vendors around the world, including firms that you have not heard of. You are told by a former Lancelot employee that these vendors operate with divergent security requirements and protocols.
o The company s proprietary recovery process for shale oil is stored on servers among a variety of less-sensitive information that can be accessed not only by scientists, but by personnel of all types at most company locations.
o DES is the strongest encryption algorithm currently used for any file.
o Several company facilities lack physical security controls beyond visitor check-in, which familiar vendors often bypass.
o Fixing all of this will take work, but first you need to grasp the scope of the mess and formulate a plan of action to address it.
Which is true regarding the type of encryption Lancelot uses?
SCENARIO
WebTracker Limited is a cloud-based online marketing service located in London. Last year, WebTracker migrated its IT infrastructure to the cloud provider AmaZure, which provides SQL Databases and Artificial Intelligence services to WebTracker. The roles and responsibilities between the two companies have been formalized in a standard contract, which includes allocating the role of data controller to WebTracker.
The CEO of WebTracker, Mr. Bond, would like to assess the effectiveness of AmaZure's privacy controls, and he recently decided to hire you as an independent auditor. The scope of the engagement is limited only to the marketing services provided by WebTracker, you will not be evaluating any internal data processing activity, such as HR or Payroll.
This ad-hoc audit was triggered due to a future partnership between WebTracker and SmartHome - a partnership that will not require any data sharing. SmartHome is based in the USA, and most recently has dedicated substantial resources to developing smart refrigerators that can suggest the recommended daily calorie intake based on DNA information. This and other personal data is collected by WebTracker.
To get an idea of the scope of work involved, you have decided to start reviewing the company's documentation and interviewing key staff to understand potential privacy risks.
The results of this initial work include the following notes:
* There are several typos in the current privacy notice of WebTracker, and you were not able to find the privacy notice for SmartHome.
* You were unable to identify all the sub-processors working for SmartHome. No subcontractor is indicated in the cloud agreement with AmaZure, which is responsible for the support and maintenance of the cloud infrastructure.
* There are data flows representing personal data being collected from the internal employees of WebTracker, including an interface from the HR system.
* Part of the DNA data collected by WebTracker was from employees, as this was a prototype approved by the CEO of WebTracker.
* All the WebTracker and SmartHome customers are based in USA and Canada.
Based on the initial assessment and review of the available data flows, which of the following would be the most important privacy risk you should investigate first?
