CIPM Practice Online

Question 1

SCENARIO

Please use the following to answer the next question:

Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the

development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can

be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After

having had a successful launch in the United States, the Handy Helper is about to be made available for

purchase worldwide.

The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the

whole family, including children, but does not provide any further detail or privacy notice. In order to use the

application, a family creates a single account, and the primary user has access to all information about the

other users. Upon start up, the primary user must check a box consenting to receive marketing emails from

Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.

Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European

distributor of Handy Helper when he fielded many questions about the product from the distributor. Sanjay

needed to look more closely at the product in order to be able to answer the questions as he was not involved

in the product development process.

In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's

sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is

stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the

product. This data is all stored in the cloud and is encrypted both during transmission and at rest.

Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent

Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is

hoping that at some point in the future, the data will reveal insights that could be used to create a fully

automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is

considered a long-term goal.

What step in the system development process did Manasa skip?

A : Obtain express written consent from users of the Handy Helper regarding marketing

B : Work with Sanjay to review any necessary privacy requirements to be built into the product

C : Certify that the Handy Helper meets the requirements of the EU-US Privacy Shield Framework

D : Build the artificial intelligence feature so that users would not have to input sensitive information into the Handy Helper

Answer: C

Question 2

SCENARIO -

Please use the following to answer the next question:

Today is your first day at a fast growing international real estate firm headquartered in New York, with offices in Canada and Germany. You are the firm's first ever privacy officer.

While touring the office to meet your new colleagues and learn the layout of the office, you notice piles of printing jobs left on the printer in the copy room. You also note a recycle bin and garbage can near the printers. With a quick glance, you see a completed loan application form print out with applicant name, social security number and home address lying in the recycle bin. You make a note to follow up immediately.

You are then introduced to the head of IT who gives you a warm welcome and explains his star project this year - enterprise CRM (Customer Relationship Management) mobility. He is very proud that he is leading this innovation that allows firm-wide employees to access the existing CRM database remotely from anywhere on the Internet. The business value of this mobility initiative is significant. Since he doesn't have internal web development expertise, he outsourced the development work to a small IT firm in New York that has just successfully delivered another IT initiative for the company.

After the tour you start working on a plan based on your observations. One immediate action is to schedule a meeting with the head of IT to discuss the CRM mobility project.

While reviewing the contract with the firm the CRM mobility project was outsourced to, all of the following should be mandatory EXCEPT

A : Right to audit.

B : Breach notification.

C : Security Commitment.

D : Service level agreements.

Answer: D

Question 3

SCENARIO

Please use the following to answer the next question:

You lead the privacy office for a company that handles information from individuals living in several countries

throughout Europe and the Americas. You begin that morning’s privacy review when a contracts officer sends

you a message asking for a phone call. The message lacks clarity and detail, but you presume that data was

lost.

When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating

that the vendor improperly shared information about your customers. He called the vendor and confirmed that

your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and

sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database

as promised in the contract. As a result, the vendor has lost control of the data.

The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell

you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the

mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write.

You put their offer on hold and begin to develop the text around the space constraints. You are content to let

the vendor’s logo be associated with the notification.

The notification explains that your company recently hired a vendor to store information about their most recent

experience at St. Sebastian Hospital’s Clinic for Infectious Diseases. The vendor did not encrypt the information

and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about

their information. They simply need to go to your company’s website and watch a quick advertisement, then

provide their name, email address, and month and year of birth.

You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation,

you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their

comments back and forth. The consultant who leads the incident-response team notes that it is his first day with

the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on

the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the

day, they vote to proceed with the notification you wrote and use the vendor’s postcards.

Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the

decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring

company with a convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled

a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:

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

2. Enroll someone with just their first name and the last-4 of their national identifier.

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

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

5. 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.

Regarding the credit monitoring, which of the following would be the greatest concern?

A : The vendor’s representative does not have enough experience

B : Signing a contract with CRUDLOK which lasts longer than one year

C : The company did not collect enough identifiers to monitor one’s credit

D : You are going to notify affected individuals via a letter followed by an email

Answer: A

Question 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.

What should you advise this company regarding the status of security cameras at their offices in the United

States?

A : Add security cameras at facilities that are now without them

B : Set policies about the purpose and use of the security cameras

C : Reduce the number of security cameras located inside the building.

D : Restrict access to surveillance video taken by the security cameras and destroy the recordings after a designated period of time

Answer: B

Question 5