An organization is using new technologies that will target and process personal data of EU customers. In which of the following circumstances would a privacy technologist need to support a data protection impact assessment (DPIA)?
Combining multiple pieces of information about an individual to produce a whole that is greater than the sum of its parts is called?
Which of the following became a foundation for privacy principles and practices of countries and organizations across the globe?
What element is most conducive to fostering a sound privacy by design culture in an organization?
Which of the following are the mandatory pieces of information to be included in the documentation of records of processing activities for an organization that processes personal data on behalf of another organization?
A jurisdiction requiring an organization to place a link on the website that allows a consumer to opt-out of sharing is an example of what type of requirement?
SCENARIO
Please use the following to answer the next question:
Light Blue Health (LBH) is a healthcare technology company developing a new web and mobile application that collects personal health information from electronic patient health records. The application will use machine learning to recommend potential medical treatments and medications based on information collected from anonymized electronic health records. Patient users may also share health data collected from other mobile apps with the LBH app.
The application requires consent from the patient before importing electronic health records into the application and sharing it with their authorized physicians or healthcare provider. The patient can then review and share the recommended treatments with their physicians securely through the app. The patient user may also share location data and upload photos in the app. The patient user may also share location data and upload photos in the app for a healthcare provider to review along with the health record. The patient may also delegate access to the app.
LBH’s privacy team meets with the Application development and Security teams, as well as key business stakeholders on a periodic basis. LBH also implements Privacy by Design (PbD) into the application development process.
The Privacy Team is conducting a Privacy Impact Assessment (PIA) to evaluate privacy risks during development of the application. The team must assess whether the application is collecting descriptive, demographic or any other user related data from the electronic health records that are not needed for the purposes of the application. The team is also reviewing whether the application may collect additional personal data for purposes for which the user did not provide consent.
Regarding the app, which action is an example of a decisional interference violation?
SCENARIO
Please use the following to answer next question:
EnsureClaim is developing a mobile app platform for managing data used for assessing car accident insurance claims. Individuals use the app to take pictures at the crash site, eliminating the need for a built-in vehicle camera. EnsureClaim uses a third-party hosting provider to store data collected by the app. EnsureClaim customer service employees also receive and review app data before sharing with insurance claim adjusters.
The app collects the following information:
First and last name
Date of birth (DOB)
Mailing address
Email address
Car VIN number
Car model
License plate
Insurance card number
Photo
Vehicle diagnostics
Geolocation
What would be the best way to supervise the third-party systems the EnsureClaim App will share data with?
What would be an example of an organization transferring the risks associated with a data breach?
Users of a web-based email service have their accounts breached through compromised login credentials. Which possible consequences of the breach illustrate the two categories of Calo’s Harm Dimensions?
SCENARIO
Tom looked forward to starting his new position with a U.S —based automobile leasing company (New Company), now operating in 32 states. New Company was recently formed through the merger of two prominent players, one from the eastern region (East Company) and one from the western region (West Company). Tom, a Certified Information Privacy Technologist (CIPT), is New Company's first Information Privacy and Security Officer. He met today with Dick from East Company, and Harry, from West Company. Dick and Harry are veteran senior information privacy and security professionals at their respective companies, and continue to lead the east and west divisions of New Company. The purpose of the meeting was to conduct a SWOT (strengths/weaknesses/opportunities/threats) analysis for New Company. Their SWOT analysis conclusions are summarized below.
Dick was enthusiastic about an opportunity for the New Company to reduce costs and increase computing power and flexibility through cloud services. East Company had been contemplating moving to the cloud, but West Company already had a vendor that was providing it with software-as-a-service (SaaS). Dick was looking forward to extending this service to the eastern region. Harry noted that this was a threat as well, because West Company had to rely on the third party to protect its data.
Tom mentioned that neither of the legacy companies had sufficient data storage space to meet the projected growth of New Company, which he saw as a weakness. Tom stated that one of the team's first projects would be to construct a consolidated New Company data warehouse. Tom would personally lead this project and would be held accountable if information was modified during transmission to or during storage in the new data warehouse.
Tom, Dick and Harry agreed that employee network access could be considered both a strength and a weakness. East Company and West Company had strong performance records in this regard; both had robust network access controls that were working as designed. However, during a projected year-long transition period, New Company employees would need to be able to connect to a New Company network while retaining access to the East Company and West Company networks.
Which statement is correct about addressing New Company stakeholders’ expectations for privacy?
A clinical research organization is processing highly sensitive personal data, including numerical attributes, from medical trial results. The organization needs to manipulate the data without revealing the contents to data users. This can be achieved by utilizing?
Which of the following would be an example of an "objective" privacy harm to an individual?
SCENARIO
Please use the following to answer the next question:
Chuck, a compliance auditor for a consulting firm focusing on healthcare clients, was required to travel to the client’s office to perform an onsite review of the client’s operations. He rented a car from Finley Motors upon arrival at the airport as so he could commute to and from the client’s office. The car rental agreement was electronically signed by Chuck and included his name, address, driver’s license, make/model of the car, billing rate, and additional details describing the rental transaction. On the second night, Chuck was caught by a red light camera not stopping at an intersection on his way to dinner. Chuck returned the car back to the car rental agency at the end week without mentioning the infraction and Finley Motors emailed a copy of the final receipt to the address on file.
Local law enforcement later reviewed the red light camera footage. As Finley Motors is the registered owner of the car, a notice was sent to them indicating the infraction and fine incurred. This notice included the license plate number, occurrence date and time, a photograph of the driver, and a web portal link to a video clip of the violation for further review. Finley Motors, however, was not responsible for the violation as they were not driving the car at the time and transferred the incident to AMP Payment Resources for further review. AMP Payment Resources identified Chuck as the driver based on the rental agreement he signed when picking up the car and then contacted Chuck directly through a written letter regarding the infraction to collect the fine.
After reviewing the incident through the AMP Payment Resources’ web portal, Chuck paid the fine using his personal credit card. Two weeks later, Finley Motors sent Chuck an email promotion offering 10% off a future rental.
What should Finley Motors have done to incorporate the transparency principle of Privacy by Design (PbD)?
After downloading and loading a mobile app, the user is presented with an account registration page requesting the user to provide certain personal details. Two statements are also displayed on the same page along with a box for the user to check to indicate their confirmation:
Statement 1 reads: “Please check this box to confirm you have read and accept the terms and conditions of the end user license agreement” and includes a hyperlink to the terms and conditions.
Statement 2 reads: “Please check this box to confirm you have read and understood the privacy notice” and includes a hyperlink to the privacy notice.
Under the General Data Protection Regulation (GDPR), what lawful basis would you primarily except the privacy notice to refer to?
What logs should an application server retain in order to prevent phishing attacks while minimizing data retention?
Truncating the last octet of an IP address because it is NOT needed is an example of which privacy principle?
SCENARIO
Clean-Q is a company that offers house-hold and office cleaning services. The company receives requests from consumers via their website and telephone, to book cleaning services. Based on the type and size of service, Clean-Q then contracts individuals that are registered on its resource database - currently managed in-house by Clean-Q IT Support. Because of Clean-Q's business model, resources are contracted as needed instead of permanently employed.
The table below indicates some of the personal information Clean-Q requires as part of its business operations:
Clean-Q has an internal employee base of about 30 people. A recent privacy compliance exercise has been conducted to align employee data management and human resource functions with applicable data protection regulation. Therefore, the Clean-Q permanent employee base is not included as part of this scenario.
With an increase in construction work and housing developments, Clean-Q has had an influx of requests for cleaning services. The demand has overwhelmed Clean-Q's traditional supply and demand system that has caused some overlapping bookings.
Ina business strategy session held by senior management recently, Clear-Q invited vendors to present potential solutions to their current operational issues. These vendors included Application developers and Cloud-Q’s solution providers, presenting their proposed solutions and platforms.
The Managing Director opted to initiate the process to integrate Clean-Q's operations with a cloud solution (LeadOps) that will provide the following solution one single online platform: A web interface that Clean-Q accesses for the purposes of resource and customer management. This would entail uploading resource and customer information.
If Clean-Q were to utilize LeadOps' services, what is a contract clause that may be included in the agreement entered into with LeadOps?
SCENARIO
You have just been hired by Ancillary.com, a seller of accessories for everything under the sun, including waterproof stickers for pool floats and decorative bands and cases for sunglasses. The company sells cell phone cases, e-cigarette cases, wine spouts, hanging air fresheners for homes and automobiles, book ends, kitchen implements, visors and shields for computer screens, passport holders, gardening tools and lawn ornaments, and catalogs full of health and beauty products. The list seems endless. As the CEO likes to say, Ancillary offers, without doubt, the widest assortment of low-price consumer products from a single company anywhere.
Ancillary's operations are similarly diverse. The company originated with a team of sales consultants selling home and beauty products at small parties in the homes of customers, and this base business is still thriving. However, the company now sells online through retail sites designated for industries and demographics, sites such as “My Cool Ride" for automobile-related products or “Zoomer” for gear aimed toward young adults. The company organization includes a plethora of divisions, units and outrigger operations, as Ancillary has been built along a decentered model rewarding individual initiative and flexibility, while also acquiring key assets. The retail sites seem to all function differently, and you wonder about their compliance with regulations and industry standards. Providing tech support to these sites is also a challenge, partly due to a variety of logins and authentication protocols.
You have been asked to lead three important new projects at Ancillary:
The first is the personal data management and security component of a multi-faceted initiative to unify the company’s culture. For this project, you are considering using a series of third- party servers to provide company data and approved applications to employees.
The second project involves providing point of sales technology for the home sales force, allowing them to move beyond paper checks and manual credit card imprinting.
Finally, you are charged with developing privacy protections for a single web store housing all the company’s product lines as well as products from affiliates. This new omnibus site will be known, aptly, as “Under the Sun.” The Director of Marketing wants the site not only to sell Ancillary’s products, but to link to additional products from other retailers through paid advertisements. You need to brief the executive team of security concerns posed by this approach.
If you are asked to advise on privacy concerns regarding paid advertisements, which is the most important aspect to cover?
What is the main privacy threat posed by Radio Frequency Identification (RFID)?
Granting data subjects the right to have data corrected, amended, or deleted describes?
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