A data processor that handles personal data tor multiple customers has decided to migrate its data warehouse to a third-party provider. What is the processor obligated to do prior to implementation?
Correct Answer: A
Explanation A data processor that handles personal data for multiple customers has decided to migrate its data warehouse to a third-party provider. The processor is obligated to seek approval from all in-scope data controllers prior to implementation. A data controller is an entity that determines the purposes and means of processing personal data. A data processor is an entity that processes personal data on behalf of a data controller. A third-party provider is an entity that provides services or resources to another entity, such as a cloud service provider or a hosting provider. According to various privacy laws and regulations, such as the GDPR or the CCPA, a data processor must obtain explicit consent from the data controller before engaging another processor or transferring personal data to a third country or an international organization. The consent must specify the identity of the other processor or the third country or international organization, as well as the safeguards and guarantees for the protection of personal data. The consent must also be documented in a written contract or other legal act that binds the processor to respect the same obligations as the controller. Seeking approval from all in-scope data controllers can help ensure that the processor complies with its contractual and legal obligations, respects the rights and preferences of the data subjects, and maintains transparency and accountability for its processing activities. Obtaining assurance that data subject requests will continue to be handled appropriately, implementing comparable industry-standard data encryption in the new data warehouse, or ensuring data retention periods are documented are also good practices for a data processor that migrates its data warehouse to a third-party provider, but they are not obligations prior to implementation. Rather, they are requirements or recommendations during or after implementation. Obtaining assurance that data subject requests will continue to be handled appropriately is a requirement for a data processor that processes personal data on behalf of a data controller. Data subject requests are requests made by individuals to exercise their rights regarding their personal data, such as access, rectification, erasure, restriction, portability, or objection. A data processor must assist the data controller in fulfilling these requests within a reasonable time frame and without undue delay. Implementing comparable industry-standard data encryption in the new data warehouse is a recommendation for a data processor that transfers personal data to another system or location. Data encryption is a process of transforming data into an unreadable form using a secret key or algorithm. Data encryption can help protect the confidentiality, integrity, and availability of personal data by preventing unauthorized access, disclosure, or modification. Ensuring data retention periods are documented is a requirement for a data processor that stores personal data on behalf of a data controller. Data retention periods are the durations for which personal data are kept before they are deleted or anonymized. Data retention periods must be determined by the purpose and necessity of processing personal data and must comply with legal and regulatory obligations. References: Data warehouse migration tips: preparation and discovery - Google Cloud, Plan a data warehouse migration - Cloud Adoption Framework, Migrating your traditional data warehouse platform to BigQuery ...
Question 107
Which of the following BEST ensures a mobile application implementation will meet an organization's data security standards?
Correct Answer: D
Question 108
Which of the following should an IT privacy practitioner review FIRST to understand where personal data is coming from and how it is used within the organization?
Correct Answer: B
Explanation A data inventory is a comprehensive list of the data that an organization collects, processes, stores, transfers, and disposes of. It includes information such as the type, source, location, owner, purpose, and retention period of the data. A data inventory is essential for understanding where personal data is coming from and how it is used within the organization, as well as for complying with data privacy laws and regulations. A data inventory also helps to identify and mitigate data privacy risks and gaps. References: * ISACA, CDPSE Review Manual 2021, Chapter 2: Privacy Governance, Section 2.2: Data Inventory and Data Mapping, p. 40-41. * ISACA, Data Privacy Audit/Assurance Program, Control Objective 3: Data Inventory and Classification, p. 7-81
Question 109
Which of the following processes BEST enables an organization to maintain the quality of personal data?
Correct Answer: A
Explanation The best way to maintain the quality of personal data is to implement routine automatic validation, which is a process of checking the accuracy, completeness, consistency, and timeliness of the data using automated tools or scripts. Routine automatic validation can help identify and correct any errors, anomalies, or discrepancies in the data, as well as ensure that the data meets the specified quality standards and requirements. Routine automatic validation can also help improve the efficiency and reliability of the data processing and analysis12. References: * CDPSE Exam Content Outline, Domain 3 - Data Lifecycle (Data Quality), Task 2: Implement data quality measures3. * CDPSE Review Manual, Chapter 3 - Data Lifecycle, Section 3.2 - Data Quality4.
Question 110
Which of the following is a responsibility of the audit function in helping an organization address privacy compliance requirements?
Correct Answer: B
Explanation 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.
