Which of the following is the GREATEST obstacle to conducting a privacy impact assessment (PIA)?
Correct Answer: D
Explanation 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)
Question 87
Which of the following is the GREATEST obstacle to conducting a privacy impact assessment (PIA)?
Correct Answer: D
Question 88
A privacy risk assessment identified that a third-party collects personal data on the organization's behalf. This finding could subject the organization to a regulatory fine for not disclosing this relationship. What should the organization do NEXT?
Correct Answer: D
Explanation The organization should disclose the relationship to those affected in jurisdictions where such disclosures are required, as this is the most appropriate and compliant action to take after identifying a privacy risk related to third-party data collection. Disclosing the relationship to the data subjects is a way of providing transparency and accountability, as well as respecting their rights and choices regarding their personal data. It also helps the organization avoid regulatory fines or sanctions for not complying with the applicable privacy laws or regulations that mandate such disclosures. The other options are not as effective or sufficient as disclosing the relationship, as they do not address the root cause of the risk, do not mitigate the potential harm to the data subjects, or do not align with the privacy principles and best practices. References: CDPSE Review Manual, 2021, p. 36
Question 89
Which of the following is the BEST approach for a local office of a global organization faced with multiple privacy-related compliance requirements?
Correct Answer: B
Explanation The best approach for a local office of a global organization faced with multiple privacy-related compliance requirements is to focus on the requirements with the highest organizational impact, because this will help prioritize the most critical and urgent privacy issues and risks that may affect the organization's reputation, operations, or legal obligations. Focusing on the highest impact requirements will also help allocate the resources and efforts more efficiently and effectively, as well as align the local office's privacy practices with the global organization's objectives and strategies12. References: * CDPSE Exam Content Outline, Domain 1 - Privacy Governance (Governance, Management & Risk Management), Task 3: Participate in the evaluation of privacy policies, programs and policies for their alignment with legal requirements, regulatory requirements and/or industry best practices3. * CDPSE Review Manual, Chapter 1 - Privacy Governance, Section 1.2 - Privacy Policy4.
Question 90
An organization has a policy requiring the encryption of personal data if transmitted through email. Which of the following is the BEST control to ensure the effectiveness of this policy?
Correct Answer: B
Explanation A data loss prevention (DLP) tool is a software solution that monitors, detects and prevents the unauthorized transmission or leakage of sensitive data, such as personal data, from an organization's network or devices. A DLP tool can help to ensure the effectiveness of a policy requiring the encryption of personal data if transmitted through email, by applying the following controls: * Scanning the content and attachments of outgoing emails for personal data, such as names, email addresses, biometric data, IP addresses, etc. * Blocking or quarantining emails that contain unencrypted personal data, and alerting the sender and/or the administrator of the policy violation. * Encrypting personal data automatically before sending them through email, using encryption standards and algorithms that are compliant with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA). * Generating audit logs and reports of email activities and incidents involving personal data, and providing visibility and accountability for policy compliance. The other options are less effective or irrelevant to ensure the effectiveness of the policy. Providing periodic user awareness training on data encryption is a good practice, but it does not guarantee that users will follow the policy or know how to encrypt personal data properly. Conducting regular control self-assessments (CSAs) is a useful method to evaluate the design and operation of the policy, but it does not prevent or detect policy violations in real time. Enforcing annual attestation to policy compliance is a formal way to demonstrate user commitment to the policy, but it does not verify or measure the actual level of compliance. References: * The Complexity Conundrum: Simplifying Data Security - ISACA, section 3: "Data loss prevention (DLP) solutions can help prevent unauthorized access to sensitive information by monitoring network traffic for specific keywords or patterns." * Guide to Securing Personal Data in Electronic Medium, section 3.2: "Organisations should consider implementing DLP solutions to prevent unauthorised disclosure of personal data via email." * Encryption in the Hands of End Users - ISACA, section 2: "A key goal of encryption is to protect the file even when direct access is possible or the transfer is intercepted."
