Which of the following is an IT privacy practitioner's BEST recommendation to reduce privacy risk before an organization provides personal data to a third party?
Correct Answer: C
Anonymization is a technique that removes or modifies all identifiers in a data set to prevent or limit the identification of the data subjects. Anonymization is an IT privacy practitioner's best recommendation to reduce privacy risk before an organization provides personal data to a third party, as it would protect the privacy of the data subjects by reducing the linkability of the data set with their original identity, and 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. Anonymization would also preserve some characteristics or patterns of the original data that can be used for analysis or research purposes by the third party, without compromising the accuracy or quality of the results. The other options are not as effective as anonymization in reducing privacy risk before an organization provides personal data to a third party. Tokenization is a technique that replaces sensitive or confidential data with non-sensitive tokens or placeholders that do not reveal the original data, but it does not prevent or limit the identification of the data subjects, as tokens can be reversed or linked back to the original data using a tokenization system or key. Aggregation is a technique that combines individual data into groups or categories that do not reveal the identity of the data subjects, but it may not prevent or limit the identification of the data subjects, as aggregated data can be de-aggregated or re-identified using other sources of information or techniques. Encryption is a technique that transforms plain text data into cipher text using an algorithm and a key, making it unreadable by unauthorized parties, but it does not prevent or limit the identification of the data subjects, as encrypted data can be decrypted or linked back to the original data using an encryption system or key1, p. 74-75 Reference: 1: CDPSE Review Manual (Digital Version)
Question 47
Who is ULTIMATELY accountable for the protection of personal data collected by an organization?
Correct Answer: B
The data owner is the person or entity who has the ultimate authority and responsibility for the protection of personal data collected by an organization. The data owner defines the purpose, scope, classification, and retention of the personal data, as well as the rights and obligations of the data subjects and other parties involved in the data processing. The data owner also ensures that the personal data is handled in compliance with the applicable privacy laws and regulations, as well as the organization's privacy policies and standards. The data owner may delegate some of the operational tasks to the data processor, data custodian, or data protection officer, but the accountability remains with the data owner.
Question 48
Which of the following is MOST important to include in a data use policy?
Correct Answer: A
Explanation A data use policy is a document that defines the rules and guidelines for how personal data are collected, used, stored, shared and deleted by an organization. It is an important part of data governance and compliance, as it helps to ensure that personal data are handled in a lawful, fair and transparent manner, respecting the rights and preferences of data subjects. A data use policy should include the requirements for collecting and using personal data, such as the legal basis, the purpose, the scope, the consent, the data minimization, the accuracy, the security and the accountability. These requirements help to establish the legitimacy and necessity of data processing activities, and to prevent unauthorized or excessive use of personal data. References: ISACA Privacy Notice & Usage Disclosures, section 2.1: "We collect Personal Information from you when you provide it to us directly or through a third party who has assured us that they have obtained your consent." Chapter Privacy Policy - Singapore Chapter - ISACA, section 2: "We will collect your personal data in accordance with the PDPA either directly from you or your authorized representatives, and/or through our third party service providers." Data Minimization-A Practical Approach - ISACA, section 2: "Enterprises may only collect as much data as are necessary for the purposes defined at the time of collection, which may also be set out in a privacy notice (sometimes referred to as a privacy statement, a fair processing statement or a privacy policy)." Establishing Enterprise Roles for Data Protection - ISACA, section 3: "Data governance is typically implemented in organizations through policies, guidelines, tools and access controls."
Question 49
An organization is considering whether to expand its operations into additional international jurisdictions. After performing a privacy risk assessment, the organization decides not to begin operating in those jurisdictions. Which of the following BEST describes this type of risk response?
Correct Answer: A
CDPSE/ISACA risk response taxonomy defines risk avoidance as deciding not to engage in the activity that gives rise to the risk. Reduction/mitigation (B/D) means proceed with controls; acceptance (C) means proceed without additional treatment. Not expanding is classic avoidance. Key CDPSE-aligned phrasing (short extract): "Risk avoidance: Discontinue or do not initiate activities that create risk."
Question 50
An organization is considering the use of remote employee monitoring software. Which of the following is the MOST important privacy consideration when implementing this solution?
Correct Answer: C
Explanation Remote employee monitoring software is a solution that collects, analyzes and reports data on the activities and behaviors of employees who work remotely or from home. It can help organizations to measure and improve employee productivity, performance, engagement and security. However, it also poses significant privacy risks and challenges, as it may involve the collection and processing of personal data, such as names, email addresses, biometric data, IP addresses, keystrokes, screenshots, web browsing history, app usage, communication content and frequency, etc. Data access should be restricted based on roles, meaning that only authorized and legitimate parties should be able to access and use the data collected by the remote employee monitoring software, based on their roles and responsibilities within the organization. This is a key privacy principle and practice that helps to protect the privacy rights and interests of the employees, and to prevent unauthorized or excessive access, use, disclosure or modification of their personal data by the organization or third parties. Data access restriction based on roles also helps to comply with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which require data controllers and processors to implement appropriate technical and organizational measures to safeguard personal data. References: Mobile Workforce Security Considerations and Privacy - ISACA, section 3: "The principle of least privilege should be applied to ensure that only authorized personnel have access to the data." Why Employee Privacy Matters More Than Ever - ISACA, section 3: "Privacy-first monitoring should include granular privacy controls, including: Auto-redacting personal information; Restricting access to sensitive information based on role; Masking sensitive information from view."
