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Latest CIPM Study Guide - 2025 First-grade CIPM: Authorized Certified Information Privacy Manager (CIPM) Pdf
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To be eligible for the CIPM certification exam, candidates must have at least two years of experience in privacy management or a related field. They must also complete the IAPP CIPM training course or have an equivalent level of knowledge and experience. Once certified, CIPM professionals must maintain their certification by earning continuing education credits every two years.
IAPP Certified Information Privacy Manager (CIPM) Sample Questions (Q59-Q64):
NEW QUESTION # 59
SCENARIO
Please use the following to answer the next QUESTION:
John is the new privacy officer at the prestigious international law firm - A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe.
During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor - MessageSafe. Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.
John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.
At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime. Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution. Furthermore, the off-premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.
Which of the following is the most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP?
- A. MessageSafe must apply due diligence before trusting Cloud Inc. with the personal data received from A&M LLP.
- B. MessageSafe must notify A&M LLP of a data breach.
- C. MessageSafe must flow-down its data protection contract terms with A&M LLP to Cloud Inc.
- D. MessageSafe must apply appropriate security controls on the cloud infrastructure.
Answer: D
Explanation:
The most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP is to require MessageSafe to apply appropriate security controls on the cloud infrastructure. This control ensures that MessageSafe takes responsibility for securing the personal data that it processes on behalf of A&M LLP on the cloud platform provided by Cloud Inc. According to the GDPR, data processors must implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing personal data1 These measures may include encryption, pseudonymisation, access control, backup and recovery, logging and monitoring, vulnerability management, incident response, etc2 Furthermore, data processors must ensure that any sub-processors they engage to process personal data on behalf of the data controller also comply with the same obligations3 Therefore, MessageSafe must ensure that Cloud Inc. provides adequate security guarantees for the cloud infrastructure and services that it uses to host the email continuity service for A&M LLP. MessageSafe must also monitor and audit the security performance of Cloud Inc. and report any issues or breaches to A&M LLP. Reference: 1: Article 32 GDPR | General Data Protection Regulation (GDPR); 2: Guidelines 4/2019 on Article 25 Data Protection by Design and by Default | European Data Protection Board; 3: Article 28 GDPR | General Data Protection Regulation (GDPR)
NEW QUESTION # 60
SCENARIO
Please use the following to answer the next QUESTION:
Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.
Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal data. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.
Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following day, to get insight into how the office computer system is currently set-up and managed.
Richard needs to closely monitor the vendor in charge of creating the firm's database mainly because of what?
- A. The vendor may not be aware of the privacy implications involved in the project.
- B. The vendor may not be forthcoming about the vulnerabilities of the database.
- C. The vendor will be in direct contact with all of the law firm's personal data.
- D. The vendor will be required to report any privacy violations to the appropriate authorities.
Answer: C
Explanation:
The main reason why Richard needs to closely monitor the vendor in charge of creating the firm's database is that the vendor will be in direct contact with all of the law firm's personal data. This means that the vendor will have access to sensitive and confidential information about the law firm's clients, such as their financial and medical data, which could expose them to identity theft, fraud, or other harms if mishandled or breached.
Therefore, Richard needs to ensure that the vendor follows the best practices of data protection and security, such as:
* Signing a data processing agreement that specifies the scope, purpose, duration, and terms of the data processing activities, as well as the rights and obligations of both parties.
* Implementing appropriate technical and organizational measures to protect the data from unauthorized or unlawful access, use, disclosure, alteration, or destruction, such as encryption, access control, backup and recovery, logging and monitoring, etc.
* Complying with the relevant laws and regulations that govern the collection, use, transfer, and retention of personal data, such as the GDPR or other local privacy laws.
* Reporting any data breaches or incidents to the law firm and the relevant authorities as soon as possible and taking corrective actions to mitigate the impact and prevent recurrence.
* Deleting or returning the data to the law firm after the completion of the project or upon request.
NEW QUESTION # 61
Which statement is FALSE regarding the use of technical security controls?
- A. Most privacy legislation lists the types of technical security controls that must be implemented.
- B. Technical security controls deployed for one jurisdiction often satisfy another jurisdiction.
- C. Technical security controls are part of a data governance strategy.
- D. A person with security knowledge should be involved with the deployment of technical security controls.
Answer: A
Explanation:
The statement that is false regarding the use of technical security controls is that most privacy legislation lists the types of technical security controls that must be implemented. Technical security controls are the hardware and software components that protect a system against cyberattacks, such as encryption, firewalls, antivirus software, and access control mechanisms1 However, most privacy legislation does not prescribe specific types of technical security controls that must be implemented by organizations. Instead, they usually require organizations to implement reasonable or appropriate technical security measures to protect personal data from unauthorized or unlawful access, use, disclosure, alteration, or destruction23 The exact level and type of technical security controls may depend on various factors, such as the nature and sensitivity of the data, the risks and threats involved, the state of the art technology available, and the cost and feasibility of implementation4 Therefore, organizations have some flexibility and discretion in choosing the most suitable technical security controls for their data processing activities. Reference: 1: Technical Controls - Cybersecurity Resilience - Resilient Energy Platform; 2: [General Data Protection Regulation (GDPR) - Official Legal Text], Article 32; 3: [Privacy Act 1988], Schedule 1 - Australian Privacy Principles (APPs), APP 11; 4: Technical Security Controls: Encryption, Firewalls & More
NEW QUESTION # 62
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.
What information will be LEAST crucial from a privacy perspective in Penny's review of vendor contracts?
- A. Pricing for data security protections
- B. The data a vendor will have access to
- C. Audit rights
- D. Liability for a data breach
Answer: A
Explanation:
The information that will be least crucial from a privacy perspective in Penny's review of vendor contracts is the pricing for data security protections ©. This is because the pricing for data security protections is a business decision that does not directly affect the privacy rights and obligations of Ace Space and its customers. The pricing for data security protections may be relevant for budgeting and negotiating purposes, but it does not determine the level or adequacy of data security measures that the vendor must provide to protect personal data.
The other options are more crucial from a privacy perspective in Penny's review of vendor contracts. Audit rights (A) are important to ensure that Ace Space can monitor and verify the vendor's compliance with the contract terms and the applicable privacy laws and regulations. Audit rights allow Ace Space to access the vendor's records, systems, policies and procedures related to personal data processing and to conduct inspections or assessments as needed. Liability for a data breach (B) is important to allocate the responsibility and consequences of a data breach involving personal data that the vendor processes on behalf of Ace Space.
Liability for a data breach may include indemnification, compensation, notification, remediation and termination clauses that protect Ace Space's interests and obligations in the event of a data breach. The data a vendor will have access to (D) is important to define the scope, purpose, duration and conditions of the personal data processing that the vendor will perform for Ace Space. The data a vendor will have access to may include the categories, types, sources, recipients and retention periods of personal data that the vendor will collect, store, use or share on behalf of Ace Space.
References:
CIPM Body of Knowledge Domain II: Privacy Program Operational Life Cycle - Task 3: Implement privacy program components - Subtask 3: Establish third-party processor management program CIPM Study Guide - Chapter 4: Privacy Program Operational Life Cycle - Section 4.3: Third-Party Processor Management
NEW QUESTION # 63
SCENARIO
Please use the following to answer the next QUESTION:
Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.
Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal dat a. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.
Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following day, to get insight into how the office computer system is currently set-up and managed.
Which of the following policy statements needs additional instructions in order to further protect the personal data of their clients?
- A. All faxes sent from the office must be documented and the phone number used must be double checked to ensure a safe arrival.
- B. When sending a print job containing personal data, the user must not leave the information visible on the computer screen following the print command and must retrieve the printed document immediately.
- C. All unused copies, prints, and faxes must be discarded in a designated recycling bin located near the work station and emptied daily.
- D. Before any copiers, printers, or fax machines are replaced or resold, the hard drives of these devices must be deleted before leaving the office.
Answer: C
Explanation:
The policy statement that needs additional instructions in order to further protect the personal data of their clients is: All unused copies, prints, and faxes must be discarded in a designated recycling bin located near the work station and emptied daily. This policy statement is insufficient because it does not specify how the unused copies, prints, and faxes should be discarded. Simply throwing them into a recycling bin may expose them to unauthorized access or theft by anyone who has access to the bin or its contents. Furthermore, emptying the bin daily may not be frequent enough to prevent accumulation or overflow of sensitive documents.
To further protect the personal data of their clients, this policy statement should include additional instructions such as:
All unused copies, prints, and faxes must be shredded before being discarded in a designated recycling bin located near the work station.
The recycling bin must be locked or secured at all times when not in use.
The recycling bin must be emptied at least twice a day or whenever it is full.
These additional instructions would ensure that the unused copies, prints, and faxes are destroyed in a secure manner and that the recycling bin is not accessible to unauthorized persons or prone to overflow.
The other policy statements do not need additional instructions, as they already provide adequate measures to protect the personal data of their clients. Documenting and double-checking the phone number for faxes ensures that the faxes are sent to the correct and intended recipient. Deleting the hard drives of copiers, printers, or fax machines before replacing or reselling them prevents data leakage or recovery by third parties. Not leaving the information visible on the computer screen and retrieving the printed document immediately prevents data exposure or theft by anyone who can see the screen or access the printer.
NEW QUESTION # 64
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