IAPP CIPM Exam Dumps

A.   Analyze the data inventory to map data flows

Answer DescriptionExplanation:
The best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has is to analyze the data inventory to map data flows. A data inventory is a comprehensive record of the personal data that an organization collects, stores, uses and shares. It helps to identify the sources, categories, locations, recipients and retention periods of personal data. A data flow map is a visual representation of how personal data flows within and outside an organization. It helps to identify the data transfers, processing activities, legal bases, risks and safeguards of personal data.
By analyzing the data inventory and mapping the data flows, Penny can gain a clear picture of the personal data lifecycle at Ace Space and identify any gaps or issues that need to be addressed. For example, she can determine whether Ace Space has a lawful basis for processing personal data of EU customers, whether it has adequate security measures to protect personal data from unauthorized access or loss, whether it has appropriate contracts with its vendors and cloud providers to ensure compliance with applicable laws and regulations, and whether it has mechanisms to respect the rights and preferences of its customers.
The other options are not the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has. Auditing all vendors’ privacy practices and safeguards (B) is an important step to ensure that Ace Space’s third-party processors are complying with their contractual obligations and legal requirements, but it does not provide a comprehensive overview of Ace Space’s own personal data processing activities. Conducting a Privacy Impact Assessment (PIA) for the company © is a useful tool to assess the privacy risks and impacts of a specific project or initiative involving personal data, but it does not provide a baseline understanding of the existing personal data landscape at Ace Space. Reviewing all cloud contracts to identify the location of data servers used (D) is a relevant aspect of understanding the location of personal data, but it does not cover other aspects such as classification and processing purpose.

A.   A second-party of supplier audit

Answer DescriptionExplanation: This answer is the best process to answer Albert’s questions about the vendor’s data security safeguards, as it can provide a direct and comprehensive way to assess and verify the vendor’s compliance with the applicable laws, regulations, standards and best practices for data protection. A second-party or supplier audit is conducted by the organization that hires or contracts the vendor to evaluate their performance and alignment with the organization’s standards and expectations. A second-party or supplier audit can also help to identify any gaps, weaknesses or risks in the vendor’s data security safeguards, and to recommend or require any improvements or corrective actions.

B.   Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released.

Answer DescriptionExplanation: Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released. This means that Sanjay should collaborate with Manasa and her product team to evaluate the privacy implications of the product and address any gaps or issues before launching it in Europe. This could involve conducting a PIA, applying the PbD principles, revising the consent mechanism, updating the privacy notice, ensuring compliance with data localization requirements, implementing data security measures, and limiting data access based on the least privilege principle. By doing so, Sanjay could help minimize the risks of offering the product in Europe and avoid potential violations of the General Data Protection Regulation (GDPR) or other local laws that could result in fines, lawsuits, or loss of trust.

A.   The number of security patches applied to company devices.

Answer DescriptionExplanation: The number of security patches applied to company devices might be the least relevant metric for a company’s privacy and governance team after a data breach. While security patches are important for preventing future breaches, they do not directly measure the impact or response of the current breach. The other metrics are more relevant for assessing how the company handled the breach, such as how it complied with the privacy rights of affected individuals, how it evaluated the privacy risks of its systems, and how it trained its employees on data awareness.

A.   Practicing data minimalism.

Answer DescriptionExplanation:
The important principle of Data Lifecycle Management (DLM) that will most likely be compromised if Anton executes his plan to limit data access to himself and Kenneth is ensuring data retrievability. Data retrievability refers to the ability to access and use data when needed for business purposes or legal obligations1 It involves maintaining the availability, integrity, and usability of data throughout its lifecycle2 However, if Anton restricts data access to only himself and Kenneth, he will create a single point of failure and a bottleneck for data retrieval. This could pose several risks and challenges for the company, such as:

• Losing data if Anton or Kenneth forgets the password or leaves the company without sharing it with others.
• Delaying data retrieval if Anton or Kenneth is unavailable or unresponsive when someone else needs the data urgently.
• Violating data protection laws or regulations that require data access by certain parties or authorities under certain circumstances.
• Reducing data quality or accuracy if Anton or Kenneth fails to update or maintain the data properly.
• Missing business opportunities or insights if Anton or Kenneth does not share the data with other relevant stakeholders or departments.

Therefore, Anton should reconsider his plan and adopt a more balanced and secure approach to data access management that follows the principle of least privilege. This means granting data access only to those who need it for their specific roles and responsibilities and revoking it when no longer needed3 He should also implement proper authentication, authorization, encryption, backup, and audit mechanisms to protect the data from unauthorized or unlawful access, use, disclosure, alteration, or destruction.

D.   A responsible internal stakeholder

Answer DescriptionExplanation: This answer is the key factor that lays the foundation for all other elements of a privacy program, as it can help to establish leadership, accountability and support for the privacy program within the organization. A responsible internal stakeholder is a person or group who has authority, influence or interest in the organization’s data processing activities, such as senior management, board members, business units or departments. A responsible internal stakeholder can help to define and communicate the organization’s vision, mission and goals for privacy protection, allocate resources and budget for the privacy program, approve and endorse privacy policies and procedures, monitor and evaluate privacy program performance and compliance, and resolve any issues or conflicts that may arise from data processing activities.

D.   Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.

Answer DescriptionExplanation: Distributing a phishing exercise to all employees is not advisable to do if your organization has a recurring issue with colleagues not reporting personal data breaches. A phishing exercise is a simulated attack that tests the awareness and response of employees to malicious emails that attempt to obtain sensitive information or compromise systems. While phishing exercises can be useful to train employees on how to recognize and avoid phishing attacks, they are not directly related to the issue of reporting personal data breaches. The other options are more appropriate to address the root cause of the issue, communicate the expectations and procedures for reporting breaches, and provide specific training to areas where breaches are happening.

D.   Shift attention to privacy for emerging technologies as the company begins to use them

Answer DescriptionExplanation:
Shifting attention to privacy for emerging technologies as the company begins to use them is a logical next step to help ensure a high level of protection. Emerging technologies, such as artificial intelligence, biometrics, blockchain, cloud computing, internet of things, etc., may pose new challenges and opportunities for privacy and data protection. They may involve new types, sources, uses, and flows of personal data that require different or additional safeguards and controls. They may also introduce new risks or impacts for individuals’ rights and interests that require careful assessment and mitigation. Therefore, it is important for the company to consider and address the privacy implications of emerging technologies as they adopt or integrate them into their products, services, or processes.
The other options are not as logical or effective as shifting attention to privacy for emerging technologies for ensuring a high level of protection. Brainstorming methods for developing an enhanced privacy framework may not be necessary or feasible if the company already has established new best practices for the industry. Developing a strong marketing strategy to communicate the company’s privacy practices may not be sufficient or relevant for ensuring a high level of protection, as it may not reflect the actual state or quality of the privacy program. Focusing on improving the incident response plan in preparation for any breaks in protection may be too reactive or narrow in scope, as it may not cover other aspects or dimensions of privacy and data protection that require continuous monitoring and improvement.