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Share some CIPM exam online questions below.
1.Which of the following is NOT typically a function of a Privacy Officer?
A. Managing an organization's information security infrastructure.
B. Serving as an interdepartmental liaison for privacy concerns.
C. Monitoring an organization's compliance with privacy laws.
D. Responding to information access requests from the public.
Answer: A
Explanation:
This answer is not typically a function of a Privacy Officer, as it is usually performed by a separate
role or department that is responsible for the technical aspects of data protection, such as the Chief
Information Security Officer (CISO) or the Information Security Manager. A Privacy Officer is more
focused on the legal, regulatory and ethical aspects of data protection, such as ensuring compliance
with privacy laws and regulations, developing and implementing privacy policies and procedures,
conducting privacy impact assessments and audits, providing privacy training and awareness, and
handling privacy incidents or breaches.

2.Which most accurately describes the reasons an organization will conduct a PIA?
A. To assess an organization's compliance with applicable laws, regulations, standards, and internal
procedures.
B. To establish an inventory of its data processing activities in compliance with Article 30 of the
GDPR.
C. To identify and reduce the privacy risks to individuals at the commencement of a project.
D. To analyze the impact of an incident response and determine next steps.
Answer: C
Explanation:
Step-by-Step Comprehensive Detailed Explanation with All Information Privacy Manager CIPM Study
Guide References
A Privacy Impact Assessment (PIA) is conducted to identify and mitigate privacy risks. Let’s review
the options:
A. To assess compliance with applicable laws, regulations, standards, and procedures:
This describes an audit or compliance assessment, not the primary purpose of a PIA.
B. To establish an inventory of its data processing activities in compliance with Article 30 of the
GDPR:
This aligns with the GDPR requirement for maintaining records of processing activities (ROPA), but it
is not the primary focus of a PIA.
C. To identify and reduce the privacy risks to individuals at the commencement of a project: This is
the core purpose of a PIA, which aims to evaluate and minimize risks to individuals' data privacy early
in a project’s lifecycle.
D. To analyze the impact of an incident response and determine next steps:
This describes a post-breach analysis, not the purpose of a PIA.
CIPM Study Guide References:
Privacy Program Operational Life Cycle C "Assess" phase emphasizes PIAs as tools for identifying
and mitigating risks to personal data.
GDPR compliance guidance also identifies PIAs as necessary for high-risk processing activities under
Article 35.

3.Under the General Data Protection Regulation (GDPR), when would a data subject have the right to
require the erasure of his or her data without undue delay?
A. When the data subject is a public authority.
B. When the erasure is in the public interest.
C. When the processing is carried out by automated means.
D. When the data is no longer necessary for its original purpose.
Answer: D
Explanation:
This answer is one of the situations when a data subject would have the right to require the erasure of
his or her data without undue delay under the General Data Protection Regulation (GDPR), which is
also known as the right to be forgotten or the right to erasure. This right allows a data subject to
request that a data controller deletes his or her personal data when one of the following grounds
applies:
The data is no longer necessary for its original purpose.
The data subject withdraws his or her consent for processing.
The data subject objects to processing based on legitimate interests or direct marketing.
The processing is unlawful or violates other laws or regulations.
The processing is related to online services offered to children.

4.SCENARIO
Please use the following to answer the next QUESTION:
Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the
company, Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year,
news broke that a police sting operation had revealed a drug ring operating in the Providence, Rhode
Island office in the United States. Video from the office's video surveillance cameras leaked to news
operations showed a drug exchange between Special Handling staff and undercover officers.
In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that
upper management believed had let the criminal elements conduct their illicit transactions. After a few
weeks under Kelly's direction, the office became a model of efficiency and customer service. Kelly
monitored his workers' activities using the same cameras that had recorded the illegal conduct of their
former co-workers.
Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The
company has received numerous reports of the staff leaving the office unattended. When Kelly
arrived, he found that even when present, the staff often spent their days socializing or conducting
personal business on their mobile phones. Again, he observed their behaviors using surveillance
cameras. He issued written reprimands to six staff members based on the first day of video alone.
Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data
Protection Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was
told that the company's license for the cameras listed facility security as their main use, but he does
not know why this matters. He has pointed out to his superiors that the company's training programs
on privacy protection and data collection mention nothing about surveillance video.
You are a privacy protection consultant, hired by the company to assess this incident, report on the
legal and compliance issues, and recommend next steps.
Knowing that the regulator is now investigating, what would be the best step to take?
A. Consult an attorney experienced in privacy law and litigation.
B. Use your background and knowledge to set a course of action.
C. If you know the organization is guilty, advise it to accept the punishment.
D. Negotiate the terms of a settlement before formal legal action takes place.
Answer: A
Explanation:
This answer is the best step to take knowing that the regulator is now investigating, as it can help the
organization to obtain legal advice and representation on how to respond to and cooperate with the
investigation, as well as how to defend or resolve any potential claims or disputes that may arise from
the incident. Consulting an attorney experienced in privacy law and litigation can also help the
organization to understand its rights and obligations under the applicable laws and regulations, as
well as the possible outcomes and consequences of the investigation. An attorney can also assist the
organization in preparing and submitting any required documents or evidence, communicating with
the regulator or other parties, negotiating a settlement or agreement, or challenging or appealing any
decisions or actions taken by the regulator.
Reference: IAPP CIPM Study Guide, page 871; ISO/IEC 27002:2013, section 16.1.5

5.Under the GDPR. when the applicable lawful basis for the processing of personal data is a legal
obligation with which the controller must comply. which right can the data subject exercise?
A. Right to withdraw consent.
B. Right to data portability.
C. Right to restriction.
D. Right to erasure.
Answer: C
Explanation:
Under the GDPR, when the applicable lawful basis for the processing of personal data is a legal
obligation with which the controller must comply, the data subject can exercise the right to restriction.
This means that the data subject can request the controller to limit the processing of their personal
data in certain circumstances, such as when they contest the accuracy or lawfulness of the
processing. The other rights are not applicable in this case, as they are either dependent on consent
(right to withdraw consent and right to data portability) or subject to exceptions (right to erasure).
Reference: GDPR, Articles 6(1)©, 18, 21(1).

6.Under the General Data Protection Regulation (GDPR), what must be included in a written
agreement between the controller and processor in relation to processing conducted on the
controller's behalf?
A. An obligation on the processor to report any personal data breach to the controller within 72 hours.
B. An obligation on both parties to report any serious personal data breach to the supervisory
authority.
C. An obligation on both parties to agree to a termination of the agreement if the other party is
responsible for a personal data breach.
D. An obligation on the processor to assist the controller in complying with the controller's obligations
to notify the supervisory authority about personal data breaches.
Answer: D
Explanation:
Under the GDPR, a written agreement between the controller and processor must include an
obligation on the processor to assist the controller in complying with the controller’s obligations to
notify the supervisory authority and the data subjects about personal data breaches. This is stated in
Article 28(3)(f) of the GDPR1. The other options are not required by the GDPR, although they may be
included in the agreement as additional clauses. The obligation to report any personal data breach to
the controller within 72 hours is imposed on the processor by Article 33(2) of the GDPR1, not by the
agreement. The obligation to report any serious personal data breach to the supervisory authority is
imposed on the controller by Article 33(1) of the GDPR1, not by the agreement. The termination of
the agreement in case of a personal data breach is not a mandatory provision under the GDPR, but
rather a contractual matter that may depend on the circumstances and severity of the breach.
Reference: GDPR

7.What is the name for the privacy strategy model that describes delegated decision making?
A. De-centralized.
B. De-functionalized.
C. Hybrid.
D. Matrix.
Answer: D
Explanation:
A matrix is a type of organizational structure that involves delegated decision making. In a matrix
structure, employees report to more than one manager or leader, usually based on different functions
or projects. For example, a software developer may report to both a product manager and a technical
manager. A matrix structure allows for more flexibility, collaboration, and innovation in complex and
dynamic environments.
The other options are not examples of delegated decision making structures. A de-centralized
structure involves distributing decision making authority across different levels or units of the
organization, rather than concentrating it at the top. A de-functionalized structure involves breaking
down functional silos and creating cross-functional teams or processes. A hybrid structure involves
combining elements of different types of structures, such as functional, divisional, or matrix.

8.SCENARIO
Please use the following to answer the next QUESTION:
Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so
anxious. Last week, a data processing firm used by the company reported that its system may have
been hacked, and customer data such as names, addresses, and birthdays may have been
compromised. Although the attempt was proven unsuccessful, the scare has prompted several
Nationwide Grill executives to Question the company's privacy program at today's meeting.
Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially
damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to
assure her that even if there had been an actual breach, the chances of a successful suit against the
company were slim. But Alice remained unconvinced.
Spencer C a former CEO and currently a senior advisor C said that he had always warned against the
use of contractors for data processing. At the very least, he argued, they should be held contractually
liable for telling customers about any security incidents. In his view, Nationwide Grill should not be
forced to soil the company name for a problem it did not cause.
One of the business development (BD) executives, Haley, then spoke, imploring everyone to see
reason. "Breaches can happen, despite organizations' best efforts," she remarked. "Reasonable
preparedness is key." She reminded everyone of the incident seven years ago when the large grocery
chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill
frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate
culture, built up through many years of cultivating relationships, Haley was able to successfully
manage the company's incident response.
Spencer replied that acting with reason means allowing security to be handled by the security
functions within the company C not BD staff. In a similar way, he said, Human Resources (HR) needs
to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill
employees are overwhelmed with posters, emails, and memos from both HR and the ethics
department related to the company's privacy program. Both the volume and the duplication of
information means that it is often ignored altogether.
Spencer said, "The company needs to dedicate itself to its privacy program and set regular in-person
trainings for all staff once a month."
Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local
HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.
Based on the scenario, Nationwide Grill needs to create better employee awareness of the company's
privacy program by doing what?
A. Varying the modes of communication.
B. Communicating to the staff more often.
C. Improving inter-departmental cooperation.
D. Requiring acknowledgment of company memos.
Answer: A
Explanation:
This answer is the best way to create better employee awareness of the company’s privacy program,
as it can increase the effectiveness and retention of the information by appealing to different learning
styles and preferences. Varying the modes of communication can include using different formats and
channels, such as posters, emails, memos, videos, webinars, podcasts, newsletters, quizzes, games
or interactive modules. Varying the modes of communication can also help to avoid information
overload or duplication, which may cause employees to ignore or disregard the privacy messages.
Reference: IAPP CIPM Study Guide, page 90; ISO/IEC 27002:2013, section 7.2.2

9.Which of the following is an example of Privacy by Design (PbD)?

A. A company hires a professional to structure a privacy program that anticipates the increasing
demands of new laws.
B. The human resources group develops a training program for employees to become certified in
privacy policy.
C. A labor union insists that the details of employers' data protection methods be documented in a
new contract.
D. The information technology group uses privacy considerations to inform the development of new
networking software.
Answer: D
Explanation:
This is an example of Privacy by Design (PbD), which is an approach to systems engineering that
integrates privacy into the design and development of products, services, and processes from the
outset7 PbD aims to ensure that privacy is embedded into the core functionality of any system or
service, rather than being added as an afterthought or a trade-off. PbD is based on seven
foundational principles: proactive not reactive; preventive not remedial; privacy as the default setting;
privacy embedded into design; full functionality C positive-sum, not zero-sum; end-to-end security C
full lifecycle protection; visibility and transparency C keep it open; and respect for user privacy C keep
it user-centric8

10.Formosa International operates in 20 different countries including the United States and France.
What organizational approach would make complying with a number of different regulations easier?
A. Data mapping.
B. Fair Information Practices.
C. Rationalizing requirements.
D. Decentralized privacy management.
Answer: C
Explanation:
Rationalizing requirements is an organizational approach that involves identifying and harmonizing
the common elements of different privacy regulations and standards. This can make compliance
easier and more efficient, as well as reduce the risk of conflicts or gaps in privacy protection.
Rationalizing requirements can also help to create a consistent privacy policy and culture across
different jurisdictions and business units.
Reference: CIPM Study Guide, page 23.
11.SCENARIO
Please use the following to answer the next QUESTION:
Ben works in the IT department of IgNight, Inc., a company that designs lighting solutions for its
clients. Although IgNight's customer base consists primarily of offices in the US, some individuals
have been so impressed by the unique aesthetic and energy-saving design of the light fixtures that
they have requested IgNight's installations in their homes across the globe.
One Sunday morning, while using his work laptop to purchase tickets for an upcoming music festival,
Ben happens to notice some unusual user activity on company files. From a cursory review, all the
data still appears to be where it is meant to be but he can't shake off the feeling that something is not
right. He knows that it is a possibility that this could be a colleague performing unscheduled
maintenance, but he recalls an email from his company's security team reminding employees to be on
alert for attacks from a known group of malicious actors specifically targeting the industry.
Ben is a diligent employee and wants to make sure that he protects the company but he does not
want to bother his hard-working colleagues on the weekend. He is going to discuss the matter with
this manager first thing in the morning but wants to be prepared so he can demonstrate his
knowledge in this area and plead his case for a promotion.
To determine the steps to follow, what would be the most appropriate internal guide for Ben to
review?
A. Incident Response Plan.
B. Code of Business Conduct.
C. IT Systems and Operations Handbook.
D. Business Continuity and Disaster Recovery Plan.
Answer: A
Explanation:
The most appropriate internal guide for Ben to review is the Incident Response Plan. An Incident
Response Plan is a document that outlines how an organization will respond to a security incident,
such as a data breach, a cyberattack, or a malware infection. An Incident Response Plan typically
includes:
The roles and responsibilities of the incident response team and other stakeholders
The procedures and protocols for detecting, containing, analyzing, and resolving incidents
The communication and escalation channels for reporting and notifying incidents
The tools and resources for conducting incident response activities
The criteria and methods for evaluating and improving the incident response process
An Incident Response Plan helps an organization prepare for and deal with security incidents in an
effective and efficient manner. It also helps an organization minimize the impact and damage of
security incidents, comply with legal and regulatory obligations, and restore normal operations as
soon as possible.
The other options are not as relevant or useful as the Incident Response Plan for Ben’s situation.
The Code of Business Conduct is a document that defines the ethical standards and expectations for
the organization’s employees and stakeholders. It may include some general principles or policies
related to security, but it does not provide specific guidance on how to handle security incidents. The
IT Systems and Operations Handbook is a document that describes the technical aspects and
functions of the organization’s IT systems and infrastructure. It may include some information on
security controls and configurations, but it does not provide detailed instructions on how to perform
incident response tasks. The Business Continuity and Disaster Recovery Plan is a document that
outlines how an organization will continue its critical functions and operations in the event of a
disruption or disaster, such as a natural disaster, a power outage, or a fire. It may include some
measures to protect or recover data and systems, but it does not focus on security incidents or
threats.
Reference: What Is an Incident Response Plan for IT?; Incident Response Plan (IRP) Basics
12.What is the main reason to begin with 3-5 key metrics during the program development process?
A. To avoid undue financial costs.
B. To keep the focus on the main organizational objectives.
C. To minimize selective data use.
D. To keep the process limited to as few people as possible.
Answer: B
Explanation:
This answer is the main reason to begin with 3-5 key metrics during the program development
process, as it can help to align the privacy program with the organization’s vision, mission and goals,
and to measure the progress and performance of the program against these objectives. Key metrics
are indicators that reflect the most important or critical aspects of the privacy program, such as
compliance, risk, maturity, effectiveness or value. By starting with a small number of key metrics, the
program development process can avoid being overwhelmed or distracted by too many or irrelevant
data points, and can prioritize and concentrate on the areas that matter most for the organization.

13.An organization’s internal audit team should do all of the following EXCEPT?
A. Implement processes to correct audit failures.
B. Verify that technical measures are in place.
C. Review how operations work in practice.
D. Ensure policies are being adhered to.
Answer: A
Explanation:
An organization’s internal audit team should not implement processes to correct audit failures, as this
is the responsibility of the management or the privacy office. The internal audit team should only
verify that technical measures are in place, review how operations work in practice, and ensure
policies are being adhered to. Implementing corrective actions would compromise the independence
and objectivity of the internal audit team.
Reference: CIPM Body of Knowledge, Domain III: Privacy Program Operational Life Cycle, Section A:
Assess, Subsection 1: Privacy Assessments and Audits.

14. Send a monthly email with their credit rating and offers for credit-related services at market rates.

15.Which of the following is NOT a type of privacy program metric?

A. Business enablement metrics.
B. Data enhancement metrics.
C. Value creation metrics.
D. Risk-reduction metrics.
Answer: B
Explanation:
Data enhancement metrics are not a type of privacy program metric because they do not measure the
performance, value, or risk of the privacy program. Data enhancement metrics are related to the
quality, accuracy, and completeness of the data collected and processed by the organization, which
are not directly linked to the privacy program objectives.
Reference: CIPM Body of Knowledge, Domain II: Privacy Program Governance, Section B:
Establishing a Privacy Program Framework, Subsection 2: Privacy Program Metrics.

16. Charge your company 20% of the cost of any credit restoration.
You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three
days later you sit down and document all that went well and all that could have gone better. You put it
in a file to reference the next time an incident occurs.
What is the most concerning limitation of the incident-response council?
A. You convened it to diffuse blame
B. The council has an overabundance of attorneys
C. It takes eight hours of emails to come to a decision
D. The leader just joined the company as a consultant
Answer: C
Explanation:
This answer is the most concerning limitation of the incident-response council, as it indicates a lack of
efficiency, urgency and coordination in handling the incident. It takes eight hours of emails to come to
a decision means that the council is wasting valuable time and resources in communicating and
resolving the incident, which may result in delayed or inadequate actions, increased harm or impact to
the affected individuals or the organization, or non-compliance with any legal or contractual
obligations or deadlines.

17. Charge your company 20% of the cost of any credit restoration.
You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three
days later you sit down and document all that went well and all that could have gone better. You put it
in a file to reference the next time an incident occurs.
Which of the following was done CORRECTLY during the above incident?
A. The process by which affected individuals sign up for email notifications
B. Your assessment of which credit monitoring company you should hire
C. The speed at which you sat down to reflect and document the incident
D. Finding a vendor who will offer the affected individuals additional services
Answer: C
Explanation:
This answer is the only thing that was done correctly during the incident, as it shows a good practice
of learning from and improving on the incident response process. The speed at which you sat down to
reflect and document the incident means that you did not delay or postpone this important step, which
can help you to capture and analyze what went well and what could have gone better during the
incident, as well as to identify any lessons learned, best practices or recommendations for future
incidents. Documenting and reflecting on the incident can also help you to update and improve your
privacy policies, procedures and safeguards, as well as to demonstrate your accountability and
compliance with any legal or contractual obligations.

18.SCENARIO
Please use the following to answer the next QUESTION:
Penny has recently joined Ace Space, a company that sells homeware accessories online, as its new
privacy officer. The company is based in California but thanks to some great publicity from a social
media influencer last year, the company has received an influx of sales from the EU and has set up a
regional office in Ireland to support this expansion. To become familiar with Ace Space’s practices
and assess what her privacy priorities will be, Penny has set up meetings with a number of
colleagues to hear about the work that they have been doing and their compliance efforts.
Penny’s colleague in Marketing is excited by the new sales and the company’s plans, but is also
concerned that Penny may curtail some of the growth opportunities he has planned. He tells her “I
heard someone in the breakroom talking about some new privacy laws but I really don’t think it
affects us. We’re just a small company. I mean we just sell accessories online, so what’s the real
risk?” He has also told her that he works with a number of small companies that help him get projects
completed in a hurry. “We’ve got to meet our deadlines otherwise we lose money. I just sign the
contracts and get Jim in finance to push through the payment. Reviewing the contracts takes time that
we just don’t have.”
In her meeting with a member of the IT team, Penny has learned that although Ace Space has taken
a number of precautions to protect its website from malicious activity, it has not taken the same level
of care of its physical files or internal infrastructure. Penny’s colleague in IT has told her that a former
employee lost an encrypted USB key with financial data on it when he left. The company nearly lost
access to their customer database last year after they fell victim to a phishing attack. Penny is told by
her IT colleague that the IT team “didn’t know what to do or who should do what. We hadn’t been
trained on it but we’re a small team though, so it worked out OK in the end.” Penny is concerned that
these issues will compromise Ace Space’s privacy and data protection.
Penny is aware that the company has solid plans to grow its international sales and will be working
closely with the CEO to give the organization a data “shake up”. Her mission is to cultivate a strong
privacy culture within the company.
Penny has a meeting with Ace Space’s CEO today and has been asked to give her first impressions
and an overview of her next steps.
To establish the current baseline of Ace Space’s privacy maturity, Penny should consider all of the
following factors EXCEPT?
A. Ace Space’s documented procedures
B. Ace Space’s employee training program
C. Ace Space’s vendor engagement protocols
D. Ace Space’s content sharing practices on social media
Answer: D
Explanation:
The factor that Penny should not consider to establish the current baseline of Ace Space’s privacy
maturity is Ace Space’s content sharing practices on social media. This is because this factor is not
directly related to the privacy program elements that Penny should assess, such as leadership and
organization, privacy risk management, engineering and information security, incident response,
individual participation, transparency and redress, privacy training and awareness, and
accountability1. The other factors are relevant to these elements and can help Penny measure the
current state of Ace Space’s privacy program against a recognized maturity model, such as the
Privacy Capability Maturity Model (PCMM) developed by the Association of Corporate Counsel2. For
example:
Ace Space’s documented procedures can help Penny evaluate the level of formalization and
standardization of the privacy policies and practices across the organization, as well as the alignment
with the applicable legal and regulatory requirements1, 2.
Ace Space’s employee training program can help Penny assess the level of awareness and
competence of the staff on privacy issues and responsibilities, as well as the effectiveness and
frequency of the training delivery and evaluation1, 2.
Ace Space’s vendor engagement protocols can help Penny determine the level of due diligence and
oversight of the third parties that process personal data on behalf of Ace Space, as well as the
contractual and technical safeguards that are in place to protect the data1, 2.

19.SCENARIO
Please use the following to answer the next QUESTION:
Your organization, the Chicago (U.S.)-based Society for Urban Greenspace, has used the same
vendor to operate all aspects of an online store for several years. As a small nonprofit, the Society
cannot afford the higher-priced options, but you have been relatively satisfied with this budget vendor,
Shopping Cart Saver (SCS). Yes, there have been some issues. Twice, people who purchased items
from the store have had their credit card information used fraudulently subsequent to transactions on
your site, but in neither case did the investigation reveal with certainty that the Society’s store had
been hacked. The thefts could have been employee-related.
Just as disconcerting was an incident where the organization discovered that SCS had sold
information it had collected from customers to third parties. However, as Jason Roland, your SCS
account representative, points
out, it took only a phone call from you to clarify expectations and the “misunderstanding” has not
occurred again.
As an information-technology program manager with the Society, the role of the privacy professional
is only one of many you play. In all matters, however, you must consider the financial bottom line.
While these problems with privacy protection have been significant, the additional revenues of sales
of items such as shirts and coffee cups from the store have been significant. The Society’s operating
budget is slim, and all sources of revenue are essential.
Now a new challenge has arisen. Jason called to say that starting in two weeks, the customer data
from the store would now be stored on a data cloud. “The good news,” he says, “is that we have
found a low-cost provider in Finland, where the data would also be held. So, while there may be a
small charge to pass through to you, it won’t be exorbitant, especially considering the advantages of
a cloud.”
Lately, you have been hearing about cloud computing and you know it’s fast becoming the new
paradigm for various applications. However, you have heard mixed reviews about the potential
impacts on privacy protection. You begin to research and discover that a number of the leading cloud
service providers have signed a letter of intent to work together on shared conventions and
technologies for privacy protection. You make a note to find out if Jason’s Finnish provider is signing
on.
What is the best way for your vendor to be clear about the Society’s breach notification expectations?
A. Include notification provisions in the vendor contract
B. Arrange regular telephone check-ins reviewing expectations
C. Send a memorandum of understanding on breach notification
D. Email the regulations that require breach notifications
Answer: A
Explanation:
This answer is the best way for Albert’s vendor to be clear about the Society’s breach notification
expectations, as it can establish clear and binding terms and conditions for both parties regarding
their roles and responsibilities for handling any data security incidents or breaches. Including
notification provisions in the vendor contract can help to define what constitutes a breach, how it
should be detected, reported and investigated, what information should be provided to the
organization and within what time frame, what actions should be taken to mitigate or resolve the
breach, and what consequences or liabilities may arise from the breach. The contract can also specify
that the vendor must cooperate and coordinate with the organization in any breach notification
activities to the relevant authorities, customers, partners or stakeholders.

20. Send an enrollment invitation to everyone the day after the contract is signed.

21.“Collection”, “access” and “destruction” are aspects of what privacy management process?
A. The data governance strategy
B. The breach response plan
C. The metric life cycle
D. The business case
Answer: C
Explanation:
The metric life cycle is a process that involves collecting, accessing, analyzing, reporting, and
destroying data. These aspects are essential for measuring the performance and effectiveness of
privacy programs.
Reference: IAPP CIPM Study Guide, page 14.
22.When implementing Privacy by Design (PbD), what would NOT be a key consideration?
A. Collection limitation.
B. Data minimization.
C. Limitations on liability.
D. Purpose specification.
Answer: C
Explanation:
Limitations on liability are not a key consideration when implementing Privacy by Design (PbD). PbD
is a methodology that aims to protect privacy by embedding it into the design of systems and data.
The key considerations for PbD are based on seven principles that include collection limitation, data
minimization, and purpose specification, among others. Limitations on liability are more relevant for
contractual or legal aspects of privacy, not for design or engineering aspects.
Reference: CIPM Study Guide, page 25; The 7 Principles of Privacy by Design.

23.SCENARIO
Please use the following to answer the next QUESTION:
As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased
with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies
following a series of relatively minor data breaches that could easily have been worse. However, you
have not had a reportable incident for the three years that you have been with the company. In fact,
you consider your program a model that others in the data storage industry may note in their own
program development.
You started the program at Consolidated from a jumbled mix of policies and procedures and worked
toward coherence across departments and throughout operations. You were aided along the way by
the program's sponsor, the vice president of operations, as well as by a Privacy Team that started
from a clear understanding of the need for change.
Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard"
among both the executive team and frontline personnel working with data and interfacing with clients.
Through the use of metrics that showed the costs not only of the breaches that had occurred, but also
projections of the costs that easily could occur given the current state of operations, you soon had the
leaders and key decision-makers largely on your side. Many of the other employees were more
resistant, but face-to-face meetings with each department and the development of a baseline privacy
training program achieved sufficient "buy-in" to begin putting the proper procedures into place.
Now, privacy protection is an accepted component of all current operations involving personal or
protected data and must be part of the end product of any process of technological development.
While your approach is not systematic, it is fairly effective.
You are left contemplating:
What must be done to maintain the program and develop it beyond just a data breach prevention
program? How can you build on your success?
What are the next action steps?
Which of the following would be most effectively used as a guide to a systems approach to
implementing data protection?
A. Data Lifecycle Management Standards.
B. United Nations Privacy Agency Standards.
C. International Organization for Standardization 9000 Series.
D. International Organization for Standardization 27000 Series.
Answer: D
Explanation:
This series of standards provides a framework for establishing, implementing, maintaining and
improving an information security management system (ISMS), which includes data protection as a
key component.
Reference: https://www.itgovernance.co.uk/blog/what-is-the-iso-27000-series-of-standards

24. Monitor each enrollee’s credit for two years from the date of enrollment.

25.SCENARIO
Please use the following to answer the next QUESTION:
Natalia, CFO of the Nationwide Grill restaurant chain, had never seen her fellow executives so
anxious. Last week, a data processing firm used by the company reported that its system may have
been hacked, and customer data such as names, addresses, and birthdays may have been
compromised. Although the attempt was proven unsuccessful, the scare has prompted several
Nationwide Grill executives to Question the company's privacy program at today's meeting.
Alice, a vice president, said that the incident could have opened the door to lawsuits, potentially
damaging Nationwide Grill's market position. The Chief Information Officer (CIO), Brendan, tried to
assure her that even if there had been an actual breach, the chances of a successful suit against the
company were slim. But Alice remained unconvinced.
Spencer C a former CEO and currently a senior advisor C said that he had always warned against the
use of contractors for data processing. At the very least, he argued, they should be held contractually
liable for telling customers about any security incidents. In his view, Nationwide Grill should not be
forced to soil the company name for a problem it did not cause.
One of the business development (BD) executives, Haley, then spoke, imploring everyone to see
reason.
"Breaches can happen, despite organizations' best efforts," she remarked. "Reasonable
preparedness is key." She reminded everyone of the incident seven years ago when the large grocery
chain Tinkerton's had its financial information compromised after a large order of Nationwide Grill
frozen dinners. As a long-time BD executive with a solid understanding of Tinkerton's's corporate
culture, built up through many years of cultivating relationships, Haley was able to successfully
manage the company's incident response.
Spencer replied that acting with reason means allowing security to be handled by the security
functions within the company C not BD staff. In a similar way, he said, Human Resources (HR) needs
to do a better job training employees to prevent incidents. He pointed out that Nationwide Grill
employees are overwhelmed with posters, emails, and memos from both HR and the ethics
department related to the company's privacy program. Both the volume and the duplication of
information means that it is often ignored altogether.
Spencer said, "The company needs to dedicate itself to its privacy program and set regular in-person
trainings for all staff once a month."
Alice responded that the suggestion, while well-meaning, is not practical. With many locations, local
HR departments need to have flexibility with their training schedules. Silently, Natalia agreed.
The senior advisor, Spencer, has a misconception regarding?
A. The amount of responsibility that a data controller retains.
B. The appropriate role of an organization's security department.
C. The degree to which training can lessen the number of security incidents.
D. The role of Human Resources employees in an organization's privacy program.
Answer: A
Explanation:
Spencer has a misconception regarding the amount of responsibility that a data controller retains, as
he suggests that the contractors should be held contractually liable for telling customers about any
security incidents, and that Nationwide Grill should not be forced to soil the company name for a
problem it did not cause. However, as a data controller, Nationwide Grill is ultimately responsible for
ensuring that the personal data of its customers is processed in compliance with applicable laws and
regulations, regardless of whether it uses contractors or not. Nationwide Grill cannot transfer or
delegate its accountability or liability to the contractors, and it has a duty to inform the customers and
the relevant authorities of any security incidents or breaches that may affect their data. Therefore,
Spencer’s view is unrealistic and risky, as it may expose Nationwide Grill to legal actions, fines,
reputational damage and loss of trust.

26.What is the main purpose of a privacy program audit?

A. To mitigate the effects of a privacy breach.
B. To justify a privacy department budget increase.
C. To make decisions on privacy staff roles and responsibilities.
D. To ensure the adequacy of data protection procedures.
Answer: D
Explanation:
This answer is the main purpose of a privacy program audit, as it can help to verify that the
organization’s data protection procedures are consistent and compliant with the applicable laws,
regulations, standards and best practices, as well as with the organization’s own policies and
objectives. A privacy program audit is a systematic and independent examination of the
organization’s privacy program records, activities and performance against established criteria. A
privacy program audit can also help to identify any gaps, weaknesses or risks in the data protection
procedures, and to recommend or implement any improvements or corrective actions.

27.SCENARIO
Please use the following to answer the next QUESTION:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner,
Anton, has found some degree of disorganization after touring the company headquarters. His uncle
Henry had always focused on production C not data processing C and Anton is concerned. In several
storage rooms, he has found paper files, disks, and old computers that appear to contain the personal
data of current and former employees and customers. Anton knows that a single break-in could
irrevocably damage the company's relationship with its loyal customers. He intends to set a goal of
guaranteed zero loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical
premises of the company. However, Kenneth C his uncle's vice president and longtime confidante C
wants to hold off on Anton's idea in favor of converting any paper records held at the company to
electronic storage. Kenneth believes this process would only take one or two years. Anton likes this
idea; he envisions a password- protected system that only he and Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job
easier, but it will simplify the management of the stored data. The heads of subsidiaries like the art
gallery and kitchenware store down the street will be responsible for their own information
management. Then, any unneeded subsidiary data still in Anton's possession can be destroyed within
the next few years.
After learning of a recent security incident, Anton realizes that another crucial step will be notifying
customers. Kenneth insists that two lost hard drives in Question are not cause for concern; all of the
data was encrypted and not sensitive in nature. Anton does not want to take any chances, however.
He intends on sending notice letters to all employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related
to privacy protection. Kenneth oversaw the development of the company's online presence about ten
years ago, but Anton is not confident about his understanding of recent online marketing laws. Anton
is assigning another trusted employee with a law background the task of the compliance assessment.
After a thorough analysis, Anton knows the company should be safe for another five years, at which
time he can order another check.
Documentation of this analysis will show auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the
effort is worth it. Anton wants his uncle's legacy to continue for many years to come.
To improve the facility's system of data security, Anton should consider following through with the
plan for which of the following?
A. Customer communication.
B. Employee access to electronic storage.
C. Employee advisement regarding legal matters.
D. Controlled access at the company headquarters.
Answer: D
Explanation:
To improve the facility’s system of data security, Anton should consider following through with the
plan for controlled access at the company headquarters. This plan would help to prevent
unauthorized physical access to the paper files, disks, and old computers that contain personal data
of employees and customers. Physical security is an important aspect of data security that involves
protecting hardware and storage devices from theft, damage, or tampering1 By placing restrictions on
who can enter the premises or access certain areas or rooms, Anton can reduce the risk of data
breaches or incidents caused by intruders or insiders2 He can also implement locks, alarms,
cameras, or guards to enhance the physical security of the facility3
Reference: 1: Physical Security: What Is It?; 2: [Physical Security: Why It’s Important & How To
Implement It]; 3: [Physical Security Best Practices: 10 Tips to Secure Your Workplace]

28.You would like to better understand how your organization can demonstrate compliance with
international privacy standards and identify gaps for remediation.
What steps could you take to achieve this objective?
A. Carry out a second-party audit.
B. Consult your local privacy regulator.
C. Conduct an annual self assessment.
D. Engage a third-party to conduct an audit.
Answer: D
Explanation:
Engaging a third-party to conduct an audit is the best way to ensure that your organization is
compliant with international privacy standards and identify any gaps that need to be remediated. An
audit should include a review of your organization's data processing activities, as well as its policies,
procedures, and internal controls. Additionally, it should include an analysis of the applicable privacy
laws and regulations. This audit will provide you with an objective third-party assessment of your
organization's compliance with international privacy standards and identify any areas of non-
compliance that need to be addressed

29.Under the General Data Protection Regulation (GDPR), which of the following situations would
LEAST likely require a controller to notify a data subject?
A. An encrypted USB key with sensitive personal data is stolen
B. A direct marketing email is sent with recipients visible in the ‘cc’ field
C. Personal data of a group of individuals is erroneously sent to the wrong mailing list
D. A hacker publishes usernames, phone numbers and purchase history online after a cyber-attack
Answer: A
Explanation:
Under the GDPR, a controller must notify a data subject of a personal data breach without undue
delay when the breach is likely to result in a high risk to the rights and freedoms of the data subject,
unless one of the following conditions applies: the personal data are rendered unintelligible to any
person who is not authorized to access it, such as by encryption; the controller has taken subsequent
measures to ensure that the high risk is no longer likely to materialize; or the notification would
involve disproportionate effort, in which case a public communication or similar measure may suffice.
In this case, an encrypted USB key with sensitive personal data is stolen, but the personal data are
presumably unintelligible to the thief, so the controller does not need to notify the data subject.
However, the controller still needs to notify the supervisory authority within 72 hours of becoming
aware of the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of
natural persons.
Reference: CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle,
Section B:
Protecting Personal Information, Subsection 2: Data Breach Incident Planning and Management
CIPM Study Guide (2021), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach
Incident Planning and Management
CIPM Textbook (2019), Chapter 8: Protecting Personal Information, Section 8.2: Data Breach Incident
Planning and Management
CIPM Practice Exam (2021), Question 134
GDPR Article 33 and 3412

30. Monitor each enrollee’s credit for two years from the date of enrollment.

31.SCENARIO
Please use the following to answer the next QUESTION:
For 15 years, Albert has worked at Treasure Box C a mail order company in the United States (U.S.)
that used to sell decorative candles around the world, but has recently decided to limit its shipments
to customers in the 48 contiguous states. Despite his years of experience, Albert is often overlooked
for managerial positions. His frustration about not being promoted, coupled with his recent interest in
issues of privacy protection, have motivated Albert to be an agent of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on
making executives aware of lapses in the company’s privacy program. He feels certain he will be
rewarded with a promotion for preventing negative consequences resulting from the company’s
outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public
Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM).
Albert thinks the model is a useful way to measure Treasure Box’s ability to protect personal data.
Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of
this model; at his interview, Albert will pledge to assist the company with meeting this level in order to
provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company’s
commitment to the security of customer and employee personal data against external threats.
However, Albert worries about the high turnover rate within the company, particularly in the area of
direct phone marketing. He sees many unfamiliar faces every day who are hired to do the marketing,
and he often hears complaints in the lunch room regarding long hours and low pay, as well as what
seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two recent security incidents. The company has responded to the
incidents with internal audits and updates to security safeguards. However, profits still seem to be
affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help
the company recover. He knows there is at least one incident the public in unaware of, although
Albert does not know the details. He believes the company’s insistence on keeping the incident a
secret could be a further detriment to its reputation. One further way that Albert wants to help
Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more
efficient procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company’s
recent business maneuvers will also impress the interviewers. For example, Albert is aware of the
company’s intention to acquire a medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he
is right for the job.
In consideration of the company’s new initiatives, which of the following laws and regulations would
be most appropriate for Albert to mention at the interview as a priority concern for the privacy team?
A. Gramm-Leach-Bliley Act (GLBA)
B. The General Data Protection Regulation (GDPR)
C. The Telephone Consumer Protection Act (TCPA)
D. Health Insurance Portability and Accountability Act (HIPAA)
Answer: D
Explanation:
The most appropriate law for Albert to mention at the interview as a priority concern for the privacy
team is the Health Insurance Portability and Accountability Act (HIPAA). HIPAA is a US federal law
that establishes national standards for the protection of sensitive patient health information. HIPAA
regulates the use, disclosure, and safeguarding of protected health information (PHI), which is any
information that can identify a patient or relate to their health or health care services. HIPAA applies
to covered entities, such as health plans, health care providers, and health care clearinghouses, and
their business associates, such as vendors, contractors, or partners that access or handle PHI on
their behalf. HIPAA requires covered entities and business associates to comply with the Privacy
Rule, which sets forth the rights of individuals and the obligations of entities regarding PHI; the
Security Rule, which specifies the administrative, technical, and physical safeguards to ensure the
confidentiality, integrity, and availability of PHI; and the Breach Notification Rule, which requires the
notification of individuals, HHS, and in some cases the media, in the event of a breach of unsecured
PHI.
Since Treasure Box intends to acquire a medical supply company in the coming weeks, it is likely that
it will become a business associate of some covered entities under HIPAA. Therefore, it will need to
ensure that its privacy program is compliant with HIPAA requirements and that it has appropriate
agreements and safeguards in place to protect PHI. Albert should mention this as a priority concern
for the privacy team and demonstrate his awareness and knowledge of HIPAA.
The other options are not as relevant or important as HIPAA for Treasure Box’s new initiatives. The
Gramm-Leach-Bliley Act (GLBA) is a US federal law that requires financial institutions to explain how
they share and protect their customers’ non-public personal information. It also repealed the Glass-
Steagall Act of 1933, which prohibited commercial banks from offering investment and insurance
services. GLBA does not apply to Treasure Box since it is not a financial institution. The General Data
Protection Regulation (GDPR) is an EU law that provides a comprehensive framework for the
protection of personal data of individuals in the EU. It imposes strict obligations and rights on data
controllers and processors regarding the collection, use, disclosure, and security of personal data.
GDPR does not apply to Treasure Box since it has recently decided to limit its shipments to
customers in the 48 contiguous states of the US. The Telephone Consumer Protection Act (TCPA) is
a US federal law that restricts telemarketing calls, text messages, faxes, and prerecorded messages.
It requires prior express consent from consumers before making such communications and provides
consumers with the right to opt out or revoke their consent. TCPA may apply to Treasure Box since it
engages in direct phone marketing, but it is not a new initiative or a priority concern for the privacy
team.
Reference: HIPAA; GLBA; GDPR; [TCPA]

32.An organization's privacy officer was just notified by the benefits manager that she accidentally
sent out the retirement enrollment report of all employees to a wrong vendor.
Which of the following actions should the privacy officer take first?
A. Perform a risk of harm analysis.
B. Report the incident to law enforcement.
C. Contact the recipient to delete the email.
D. Send firm-wide email notification to employees.
Answer: A
Explanation:
The first action that the privacy officer should take after being notified by the benefits manager that
she accidentally sent out the retirement enrollment report of all employees to a wrong vendor is to
perform a risk of harm analysis. A risk of harm analysis is a process of assessing the potential
adverse consequences for the individuals whose personal data has been compromised by a data
breach or incident5 The purpose of this analysis is to determine whether the breach or incident poses
a significant risk of harm to the affected individuals, such as identity theft, fraud, discrimination,
physical harm, emotional distress, or reputational damage6 The risk of harm analysis should consider
various factors, such as the type and amount of data involved, the sensitivity and context of the data,
the likelihood and severity of harm, the characteristics of the recipients or unauthorized parties who
accessed the data, and the mitigating measures taken or available to reduce the harm7 Based on this
analysis, the privacy officer can then decide whether to notify the affected individuals, the relevant
authorities, or other stakeholders about the breach or incident. Notification is usually required by law
or best practice when there is a high risk of harm to the individuals as a result of the breach or
incident8 Notification can also help to mitigate the harm by allowing the individuals to take protective
actions or seek remedies. Therefore, performing a risk of harm analysis is a crucial first step for
responding to a data breach or incident.
Reference: 5: Can a risk of harm itself be a harm? | Analysis | Oxford Academic; 6: No Harm Done?
Assessing Risk of Harm under the Federal Breach Notification Rule; 7: CCOHS: Hazard and Risk -
Risk Assessment; 8: Breach Notification Requirements in Canada | PrivacySense.net

33.Which is NOT an influence on the privacy environment external to an organization?

A. Management team priorities.
B. Regulations.
C. Consumer demand.
D. Technological advances.
Answer: A
Explanation:
The privacy environment external to an organization refers to the factors that are outside the control
of the organization, such as regulations, consumer demand, technological advances, and social
norms. These factors can affect the organization’s privacy practices and policies, and require the
organization to adapt and comply. Management team priorities are an internal factor that influence the
privacy environment within the organization, as they reflect the organization’s vision, mission, values,
and goals.
Reference: CIPM Study Guide, page 14.

34.SCENARIO
Please use the following to answer the next QUESTION:
For 15 years, Albert has worked at Treasure Box C a mail order company in the United States (U.S.)
that used to sell decorative candles around the world, but has recently decided to limit its shipments
to customers in the 48 contiguous states. Despite his years of experience, Albert is often overlooked
for managerial positions. His frustration about not being promoted, coupled with his recent interest in
issues of privacy protection, have motivated Albert to be an agent of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on
making executives aware of lapses in the company’s privacy program. He feels certain he will be
rewarded with a promotion for preventing negative consequences resulting from the company’s
outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public
Accountans)/CICA (Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM).
Albert thinks the model is a useful way to measure Treasure Box’s ability to protect personal data.
Albert has noticed that Treasure Box fails to meet the requirements of the highest level of maturity of
this model; at his interview, Albert will pledge to assist the company with meeting this level in order to
provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company’s
commitment to the security of customer and employee personal data against external threats.
However, Albert worries about the high turnover rate within the company, particularly in the area of
direct phone marketing. He sees many unfamiliar faces every day who are hired to do the marketing,
and he often hears complaints in the lunch room regarding long hours and low pay, as well as what
seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two recent security incidents. The company has responded to the
incidents with internal audits and updates to security safeguards. However, profits still seem to be
affected and anecdotal evidence indicates that many people still harbor mistrust. Albert wants to help
the company recover. He knows there is at least one incident the public in unaware of, although
Albert does not know the details. He believes the company’s insistence on keeping the incident a
secret could be a further detriment to its reputation. One further way that Albert wants to help
Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more
efficient procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company’s
recent business maneuvers will also impress the interviewers. For example, Albert is aware of the
company’s intention to acquire a medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he
is right for the job.
Based on Albert’s observations regarding recent security incidents, which of the following should he
suggest as a priority for Treasure Box?
A. Appointing an internal ombudsman to address employee complaints regarding hours and pay.
B. Using a third-party auditor to address privacy protection issues not recognized by the prior internal
audits.
C. Working with the Human Resources department to make screening procedures for potential
employees more rigorous.
D. Evaluating the company’s ability to handle personal health information if the plan to acquire the
medical supply company goes forward
Answer: B
Explanation:
This answer is the best suggestion that Albert should make based on his observations regarding
recent security incidents, as it can help to ensure that Treasure Box’s privacy program and practices
are assessed and verified by an independent and objective party who has the necessary expertise,
experience and credentials to evaluate the company’s compliance with the applicable laws,
regulations, standards and best practices for data protection. Using a third-party auditor can also help
to identify any gaps, weaknesses or risks that may have been overlooked or missed by the prior
internal audits, and to recommend or implement any improvements or corrective actions. A third-party
audit can also help to enhance the company’s reputation and trust among its customers, partners
and stakeholders, as well as demonstrate its commitment and accountability for privacy protection.

35. Send a monthly email with their credit rating and offers for credit-related services at market rates.
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