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IAPP CIPM Exam Sample Questions

Question # 1

What is the main function of the Asia-Pacific Economic Cooperation Privacy Framework?

A. Enabling regional data transfers.

B. Protecting data from parties outside the region.

C. Establishing legal requirements for privacy protection in the region.

D. Marketing privacy protection technologies developed in the region.

Answer

A. Enabling regional data transfers.

Explanation:

The main function of the Asia-Pacific Economic Cooperation Privacy Framework is enabling regional data transfers while protecting information privacy across APEC member economies. The Framework promotes a flexible approach to information privacy protection that avoids the creation of unnecessary barriers to information flows3 It is based on a set of common privacy principles that are consistent with the core values of the OECD Guidelines on the Protection of Privacy and Transborder Flows of Personal Data3 The Framework also provides guidance for domestic implementation and international implementation of the privacy principles through various mechanisms, such as cross-border privacy rules (CBPRs), accountability agents, regulators, enforcement cooperation, and capacity building3 The Framework aims to facilitate the safe transfer of information between economies, enhance consumer trust and confidence in online transactions and information networks, encourage the use of electronic data to enhance and expand business opportunities, and provide technical assistance to economies that have yet to address privacy from a regulatory or policy perspective4 References: 3: APEC PRIVACY PRINCIPLES; 4: APEC Data Privacy Pathfinder

Reference: [Reference: https://iapp.org/resources/article/apec-privacy-framework/, ]

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Question # 2

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 – not data processing – 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 – his uncle's vice president and longtime confidante – 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. Which important principle of Data Lifecycle Management (DLM) will most likely be compromised if Anton executes his plan to limit data access to himself and Kenneth?

A. Practicing data minimalism.

B. Ensuring data retrievability.

C. Implementing clear policies.

D. Ensuring adequacy of infrastructure.

Answer

A. Practicing data minimalism.

Explanation:
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.

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Question # 3

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. Data enhancement metrics.

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. References: CIPM Body of Knowledge, Domain II: Privacy Program Governance, Section B: Establishing a Privacy Program Framework, Subsection 2: Privacy Program Metrics.

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Question # 4

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. 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.

Explanation:

Under the GDPR, a written agreement between the controller and processor in relation to processing conducted on the controller’s behalf must include 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. This is one of the requirements under Article 28(3)(f) of the GDPR, which specifies the minimum content of such an agreement. The other options are not required by the GDPR, although they may be agreed upon by the parties as additional terms. References: GDPR, Article 28(3)(f).

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Question # 5

Which of the following best describes proper compliance for an international organization using Binding Corporate Rules (BCRs) as a controller or processor?

A. Employees must sign an ad hoc contractual agreement each time personal data is exported.

B. All employees are subject to the rules in their entirety, regardless of where the work is taking place.

C. All employees must follow the privacy regulations of the jurisdictions where the current scope of their work is established.

D. Employees who control personal data must complete a rigorous certification procedure, as they are exempt from legal enforcement.

Answer

C. All employees must follow the privacy regulations of the jurisdictions where the current scope of their work is established.

Explanation:

Binding Corporate Rules (BCRs) are a mechanism for international organizations to transfer personal data within their group of companies across different jurisdictions, in compliance with the EU General Data Protection Regulation (GDPR) and other privacy laws. BCRs are legally binding and enforceable by data protection authorities and data subjects. BCRs must ensure that all employees who process personal data follow the privacy regulations of the jurisdictions where the data originates from, regardless of where they are located or where the data is transferred to. References: [Binding Corporate Rules], [BCRs for controllers], [BCRs for processors]

Reference: [Reference: https://www.lexology.com/library/detail.aspx?g=80239951-01b8-409f-9019-953f5233852e, ]

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