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NEW QUESTION # 49
A new marketing application needs to use data from the organization's customer database. Prior to the application using the data, which of the following should be done FIRST?
- A. Renew the encryption key to include the application.
- B. Ensure the data loss prevention (DLP) tool is logging activity.
- C. De-identify all personal data in the database.
- D. Determine what data is required by the application.
Answer: D
Explanation:
Before using data from the organization's customer database for a new marketing application, the first step should be to determine what data is required by the application and for what purpose. This will help to ensure that the data collection and processing are relevant, necessary, and proportionate to the intended use, and that the data minimization principle is followed. Data minimization means that only the minimum amount of personal data needed to achieve a specific purpose should be collected and processed, and that any excess or irrelevant data should be deleted or anonymized1. This will also help to comply with the data privacy laws and regulations that apply to the organization, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which require organizations to inform data subjects about the types and purposes of data processing, and to obtain their consent if needed23.
Reference:
ISACA, Data Privacy Audit/Assurance Program, Control Objective 2: Data Minimization, p. 61 ISACA, GDPR Data Protection Impact Assessments, p. 4-52 ISACA, CCPA vs. GDPR: Similarities and Differences, p. 1-23
NEW QUESTION # 50
Which of the following scenarios should trigger the completion of a privacy impact assessment (PIA)?
- A. New data retention and backup policies
- B. New inter-organizational data flows
- C. Updates to data quality standards
- D. Updates to the enterprise data policy
Answer: B
Explanation:
Explanation
A privacy impact assessment (PIA) is a process of analyzing the potential privacy risks and impacts of collecting, using, and disclosing personal data. A PIA should be conducted when there is a change in the data processing activities that may affect the privacy of individuals or the compliance with data protection laws and regulations. One of the scenarios that should trigger the completion of a PIA is when there are new inter-organizational data flows, which means that personal data is shared or transferred between different entities or jurisdictions. This may introduce new privacy risks, such as unauthorized access, misuse, or breach of data, as well as new legal obligations, such as obtaining consent, ensuring adequate safeguards, or notifying authorities.
References:
PIA Triggers - International Association of Privacy Professionals
Privacy Impact Assessment - International Association of Privacy Professionals GDPR Privacy Impact Assessment Data Protection Impact Assessment triggers: Clarity or confusion?
NEW QUESTION # 51
Which of the following is the BEST way to ensure that application hardening is included throughout the software development life cycle (SDLC)?
- A. Include qualified application security personnel as part of the process.
- B. Require an annual third-party audit of new client software solutions.
- C. Require an annual internal audit of SDLC processes.
- D. Ensure comprehensive application security testing immediately prior to release.
Answer: A
Explanation:
The best way to ensure that application hardening is included throughout the software development life cycle (SDLC) is to include qualified application security personnel as part of the process. Application hardening is the process of applying security measures and techniques to an application to reduce its attack surface, vulnerabilities, and risks. Application hardening should be integrated into every stage of the SDLC, from planning and design to development and testing to deployment and maintenance. Including qualified application security personnel as part of the process helps to ensure that application hardening is performed effectively and consistently, as well as to provide guidance, feedback, and support to the developers, testers, and project managers. The other options are not as effective or sufficient as including qualified application security personnel as part of the process, as they do not address the root cause of the lack of application hardening, which is the gap in skills and knowledge among the SDLC participants.
NEW QUESTION # 52
Which of the following is MOST important to review before using an application programming interface (API) to help mitigate related privacy risk?
- A. Data classification
- B. Data flows
- C. Data collection
- D. Data taxonomy
Answer: B
Explanation:
Data flows are the most important to review before using an application programming interface (API) to help mitigate related privacy risk. Data flows are the paths or routes that data take from their sources to their destinations through various processes, transformations, or exchanges. Data flows can help understand how data are collected, used, shared, stored, or deleted by an API and its related applications. Data flows can also help identify the potential privacy risks or impacts that may arise from data processing activities involving an API and its related applications. Data flows can be represented by diagrams, maps, models, or documents that show the sources, destinations, types, formats, volumes, frequencies, purposes, or legal bases of data.
Data taxonomy, data classification, and data collection are also important for privacy risk mitigation when using an API, but they are not the most important. Data taxonomy is a system of organizing and categorizing data into groups, classes, or hierarchies based on their characteristics, attributes, or relationships. Data taxonomy can help understand the structure, meaning, context, or value of dat a. Data classification is a process of assigning labels or tags to data based on their sensitivity, confidentiality, criticality, or risk level. Data classification can help determine the appropriate level of protection or handling for data. Data collection is a process of gathering or obtaining data from various sources for a specific purpose or objective. Data collection can help obtain the necessary information or evidence for decision making or problem solving.
NEW QUESTION # 53
Which of the following is MOST likely to present a valid use case for keeping a customer's personal data after contract termination?
- A. A required retention period due to regulations
- B. Ease of onboarding when the customer returns
- C. For the purpose of medical research
- D. A forthcoming campaign to win back customers
Answer: A
Explanation:
Explanation
Data retention is a process of keeping personal data for a specified period of time for legitimate purposes, such as legal obligations, contractual agreements, business operations or historical records. Data retention should be based on the principle of data minimization, which requires limiting the collection, storage and processing of personal data to what is necessary and relevant for the intended purposes. Data retention should also comply with the principle of storage limitation, which requires deleting or disposing of personal data when it is no longer needed or justified. The most likely valid use case for keeping a customer's personal data after contract termination is a required retention period due to regulations, such as tax laws, financial laws, health laws or consumer protection laws, that mandate the organization to retain certain types of customer data for a certain period of time after the end of the contractual relationship. The other options are not valid use cases for keeping a customer's personal data after contract termination, as they do not meet the criteria of necessity, relevance or justification. For the purpose of medical research, the organization would need to obtain the consent of the customer or have another legal basis for processing their personal data for a different purpose than the original contract. A forthcoming campaign to win back customers or ease of onboarding when the customer returns are not legitimate purposes for retaining customer data after contract termination, as they are not related to the original contract and may violate the customer's privacy rights and preferences. , p.
99-100 References: : CDPSE Review Manual (Digital Version)
NEW QUESTION # 54
Of the following, who should be PRIMARILY accountable for creating an organization's privacy management strategy?
- A. Information security steering committee
- B. Chief data officer (CDO)
- C. Chief privacy officer (CPO)
- D. Privacy steering committee
Answer: C
Explanation:
Explanation
Some organizations, typically those that manage large amounts of personal information related to employees, customers, or constituents, will employ a chief privacy officer (CPO). Some organizations have a CPO because applicable regulations such as the Gramm-Leach-Bliley Act (GLBA) require it. Other regulations such as the Health Information Portability and Accountability Act (HIPAA), the Fair Credit Reporting Act (FCRA), and the GLBA place a slate of responsibilities upon an organization that compels them to hire an executive responsible for overseeing compliance.
The chief privacy officer (CPO) is the senior executive who is responsible for establishing and maintaining the organization's privacy vision, strategy, and program. The CPO oversees the development and implementation of privacy policies, procedures, standards, and controls, and ensures that they align with the organization's business objectives and legal obligations. The CPO also leads the privacy governance structure, such as the privacy steering committee, and coordinates with other stakeholders, such as the chief data officer (CDO), the information security steering committee, and the legal counsel, to ensure that privacy is integrated into all aspects of the organization's operations. References: : CDPSE Review Manual (Digital Version), page 21
NEW QUESTION # 55
What type of personal information can be collected by a mobile application without consent?
- A. Accelerometer data
- B. Phone number
- C. Geolocation
- D. Full name
Answer: A
Explanation:
Reference:
Accelerometer data is a type of personal information that can be collected by a mobile application without consent, according to some studies and reports. Accelerometer data measures the movement and orientation of the device, and can be used for various purposes, such as fitness tracking, gaming, navigation, and authentication. However, accelerometer data can also reveal sensitive information about the user's behavior, activity, location, and identity, without their knowledge or permission. For example, some researchers have shown that accelerometer data can be used to infer the user's gender, age, health condition, personality traits, and even passwords. Therefore, accelerometer data poses a significant privacy risk for mobile users, and there is a lack of clear and consistent regulations and guidelines on how to collect, use, and protect this type of data.
Privacy Threats through Ultrasonic Side Channels on Mobile Devices, IEEE Accelerometer Data as a Biometric Identifier, IEEE Privacy Leaks from Smartphone Motion Sensors, IEEE How Your Smartphone's Motion Sensors Can Reveal Your PIN, Forbes
NEW QUESTION # 56
Which of the following helps to ensure the identities of individuals in a two-way communication are verified?
- A. Mutual certificate authentication
- B. Secure Shell (SSH)
- C. Virtual private network (VPN)
- D. Transport Layer Security (TLS)
Answer: A
Explanation:
The best answer is D. Mutual certificate authentication.
A comprehensive explanation is:
Mutual certificate authentication is a method of mutual authentication that uses public key certificates to verify the identities of both parties in a two-way communication. A public key certificate is a digital document that contains information about the identity of the certificate holder, such as their name, organization, domain name, etc., as well as their public key, which is used for encryption and digital signature. A public key certificate is issued and signed by a trusted authority, called a certificate authority (CA), that vouches for the validity of the certificate.
Mutual certificate authentication works as follows:
Both parties have a public key certificate issued by a CA that they trust.
When they initiate a communication, they exchange their certificates with each other.
They verify the signatures on the certificates using the CA's public key, which they already have or can obtain from a trusted source.
They check that the certificates are not expired, revoked, or tampered with.
They extract the public keys from the certificates and use them to encrypt and decrypt messages or to generate and verify digital signatures.
They confirm that the identities in the certificates match their expectations and intentions.
By using mutual certificate authentication, both parties can be confident that they are communicating with the intended and legitimate party, and that their communication is secure and confidential.
Mutual certificate authentication is often used in conjunction with Transport Layer Security (TLS), a protocol that provides encryption and authentication for network communications. TLS supports both one-way and two-way authentication. In one-way authentication, only the server presents a certificate to the client, and the client verifies it. In two-way authentication, also known as mutual TLS or mTLS, both the server and the client present certificates to each other, and they both verify them. Mutual TLS is commonly used for secure web services, such as APIs or webhooks, that require both parties to authenticate each other.
Virtual private network (VPN), Secure Shell (SSH), and Transport Layer Security (TLS) are all technologies that can help to ensure the identities of individuals in a two-way communication are verified, but they are not methods of mutual authentication by themselves. They can use mutual certificate authentication as one of their options, but they can also use other methods, such as username and password, pre-shared keys, or tokens. Therefore, they are not as specific or accurate as mutual certificate authentication.
Reference:
What is mutual authentication? | Two-way authentication1
How to prove and verify someone's identity2
Identity verification - Information Security & Policy3
NEW QUESTION # 57
Which of the following is the BEST way to reduce the risk of compromise when transferring personal information using email?
- A. Password-protected .zip files
- B. Centrally managed encryption
- C. End user-managed encryption
- D. Private cloud storage space
Answer: B
Explanation:
Explanation
Encryption is a security practice that transforms data into an unreadable format using a secret key or algorithm. Encryption protects the confidentiality and integrity of data, especially when they are transferred using email or other communication channels. Encryption ensures that only authorized parties can access and use the data, while unauthorized parties cannot decipher or modify the data without the key or algorithm.
Encryption also helps to comply with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which require data controllers and processors to implement appropriate technical and organizational measures to safeguard personal data.
Centrally managed encryption is a type of encryption that is implemented and controlled by a central authority or system, such as an organization or a service provider. Centrally managed encryption has the following advantages over end user-managed encryption, private cloud storage space, or password-protected .zip files, for reducing the risk of compromise when transferring personal information using email:
It can enforce consistent and standardized encryption policies and procedures across the organization or the service, such as the encryption standards, algorithms, keys, modes, and formats.
It can automate the encryption and decryption processes for the users, without requiring them to perform any manual actions or install any software or plug-ins on their devices.
It can monitor and audit the encryption activities and incidents, and provide visibility and accountability for the data protection and compliance status.
It can reduce the human errors or negligence that may compromise the encryption security, such as losing or sharing the keys, forgetting or reusing the passwords, or sending the data to the wrong recipients.
References:
Encryption in the Hands of End Users - ISACA, section 2: "A key goal of encryption is to protect the file even when direct access is possible or the transfer is intercepted." The Complexity Conundrum: Simplifying Data Security - ISACA, section 3: "Centrally managed encryption solutions can help enterprises overcome these challenges by providing a unified platform for encrypting data across different environments and applications." Email Encryption: What You Need to Know - Lifewire, section 1: "Email encryption is a way of protecting your email messages from being read by anyone other than the intended recipients."
NEW QUESTION # 58
Which of the following is the MOST important consideration when using advanced data sanitization methods to ensure privacy data will be unrecoverable?
- A. Location of data
- B. Type of media
- C. Subject matter expertise
- D. Regulatory compliance requirements
Answer: D
NEW QUESTION # 59
Which of the following is the BEST way to protect the privacy of data stored on a laptop in case of loss or theft?
- A. Regular backups
- B. Remote wipe
- C. Endpoint encryption
- D. Strong authentication controls
Answer: B
NEW QUESTION # 60
An organization is concerned with authorized individuals accessing sensitive personal customer information to use for unauthorized purposes. Which of the following technologies is the BEST choice to mitigate this risk?
- A. Mobile device management (MDM)
- B. Email filtering system
- C. Intrusion monitoring
- D. User behavior analytics
Answer: C
NEW QUESTION # 61
When contracting with a Software as a Service (SaaS) provider, which of the following is the MOST important contractual requirement to ensure data privacy at service termination?
- A. Encryption of customer data
- B. Removal of customer data
- C. Destruction of customer data
- D. De-identification of customer data
Answer: B
Explanation:
When contracting with a SaaS provider, it is important to ensure that the provider will remove all customer data from their systems and storage devices at the end of the service contract. This will prevent any unauthorized access, use, or disclosure of the customer data by the provider or third parties after the service termination. Removal of customer data means that the data are permanently erased and cannot be recovered or restored by any means.
Reference:
ISACA, Data Privacy Audit/Assurance Program, Control Objective 9: Data Disposal, p. 16-171 ISACA, CDPSE Review Manual 2021, Chapter 4: Privacy Incident Response, Section 4.2: Data Disposal and Destruction, p. 151-152.
NEW QUESTION # 62
Which of the following would MOST effectively reduce the impact of a successful breach through a remote access solution?
- A. Regular physical and remote testing of the incident response plan
- B. Compartmentalizing resource access
- C. Monitoring and reviewing remote access logs
- D. Regular testing of system backups
Answer: B
Explanation:
Explanation
Compartmentalizing resource access is a security technique that divides a system or network into separate segments or zones with different levels of access and control, based on the sensitivity and value of the data or resources. Compartmentalizing resource access would most effectively reduce the impact of a successful breach through a remote access solution, as it would limit the scope and extent of the breach, and prevent unauthorized access to other segments or zones that contain more critical or sensitive data or resources. The other options are not as effective as compartmentalizing resource access in reducing the impact of a successful breach through a remote access solution. Regular testing of system backups is a security technique that verifies the availability and recoverability of data in case of a system failure or disaster, but it does not prevent or limit unauthorized access to data. Monitoring and reviewing remote access logs is a security technique that records and analyzes the activities and events related to remote access sessions, but it does not prevent or limit unauthorized access to data. Regular physical and remote testing of the incident response plan is a security technique that evaluates and improves the readiness and effectiveness of an organization's response to security incidents, but it does not prevent or limit unauthorized access to data1, p. 91-92 References: 1: CDPSE Review Manual (Digital Version)
NEW QUESTION # 63
Which of the following should an IT privacy practitioner do FIRST before an organization migrates personal data from an on-premise solution to a cloud-hosted solution?
- A. Develop and communicate a data security plan.
- B. Ensure strong encryption is used.
- C. Perform a privacy impact assessment (PIA).
- D. Conduct a security risk assessment.
Answer: D
NEW QUESTION # 64
Which of the following is the BEST way to ensure privacy is embedded into the training of an AI model?
- A. By obtaining consent from individuals to use their data
- B. By posting a privacy notice before login
- C. By using de-identified data
- D. By using synthetic data
Answer: D
Explanation:
Synthetic data is generated artificially to mimic patterns without containing real personal data, making it the strongest method to embed privacy by design in AI training. De-identification (A) reduces but does not eliminate reidentification risk; consent (B) addresses lawfulness, not privacy-preserving training; privacy notices (D) provide transparency but not technical risk reduction.
"Synthetic data allows AI model training without exposing real personal information."
NEW QUESTION # 65
Which of the following information would MOST likely be considered sensitive personal data?
- A. Mailing address
- B. Contact phone number
- C. Bank account login ID
- D. Ethnic origin
Answer: D
Explanation:
Explanation
Sensitive personal data is a subset of personal data that reveals or relates to more intimate or confidential aspects of a person's identity, such as their racial or ethnic origin, religious or philosophical beliefs, health status, sexual orientation, political opinions, trade union membership, biometric or genetic data, or criminal record. Sensitive personal data is subject to more stringent legal and regulatory protections and requires a higher level of consent from the data subject to be processed. Mailing address, bank account login ID, and contact phone number are examples of personal data, but not sensitive personal data, as they do not reveal or relate to such intimate or confidential aspects of a person's identity.
References: CDPSE Review Manual, 2021, p. 29
NEW QUESTION # 66
Which of the following is the PRIMARY benefit of implementing policies and procedures for system hardening?
- A. It increases system resiliency.
- B. It reduces exposure of data.
- C. It eliminates attack motivation for data.
- D. It reduces external threats to data.
Answer: A
Explanation:
System hardening is a process of applying security measures and configurations to a system to reduce its attack surface and enhance its resistance to threats. System hardening can include disabling unnecessary services, removing default accounts, applying patches and updates, enforcing strong passwords and encryption, and implementing firewalls and antivirus software. The primary benefit of system hardening is that it increases system resiliency, which is the ability of a system to withstand or recover from adverse events that could affect its functionality or performance. The other options are not the primary benefits of system hardening, although they may be secondary benefits or outcomes. System hardening does not necessarily reduce external threats to data, as threats can originate from various sources and vectors. System hardening may reduce exposure of data, but only if the data is stored or processed by the system. System hardening does not eliminate attack motivation for data, as attackers may have different motives and incentives for targeting data. , p. 91-92 Reference: : CDPSE Review Manual (Digital Version)
NEW QUESTION # 67
Which of the following is MOST important to capture in the audit log of an application hosting personal data?
- A. Server details of the hosting environment
- B. Last logins of privileged users
- C. Application error events
- D. Last user who accessed personal data
Answer: D
Explanation:
Explanation
An audit log is a record of the activities and events that occur in an information system, such as an application hosting personal data. An audit log can help to monitor, detect, investigate and prevent unauthorized or malicious access, use, modification or deletion of personal data. An audit log can also help to demonstrate compliance with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA). An audit log should capture the following information for each event: 9 The date and time of the event The identity of the user or system that performed the event The type and description of the event The outcome or result of the event The personal data that were accessed, used, modified or deleted The last user who accessed personal data is the most important information to capture in the audit log, as it can help to identify who is responsible for any data breach or misuse of personal data. It can also help to verify that only authorized and legitimate users have access to personal data, and that they follow the data use policy and the principle of least privilege. The last user who accessed personal data can also help to support data subjects' rights, such as the right to access, rectify, erase or restrict their personal data.
The other options are less important or irrelevant to capture in the audit log of an application hosting personal data. Server details of the hosting environment are not related to personal data, and they can be obtained from other sources, such as network logs or configuration files. Last logins of privileged users are important to capture in a separate audit log for user account management, but they do not indicate what personal data were accessed or used by those users. Application error events are important to capture in a separate audit log for system performance and reliability, but they do not indicate what personal data were affected by those errors.
References:
IS Audit Basics: Auditing Data Privacy, section 4: "Audit logs should be maintained for all systems that process PII." Data Protection Audit Manual, section 3.2: "Audit trails should be kept for all processing operations involving personal data." Audit Logging Best Practices, section 2: "An audit log entry should contain enough information to answer who did what and when."
NEW QUESTION # 68
How can an organization BEST ensure its vendors are complying with data privacy requirements defined in their contracts?
- A. Obtain independent assessments of the vendors' data management processes.
- B. Perform penetration tests of the vendors' data security.
- C. Review self-attestations of compliance provided by vendor management.
- D. Compare contract requirements against vendor deliverables.
Answer: A
Explanation:
Explanation
The best way for an organization to ensure its vendors are complying with data privacy requirements defined in their contracts is to obtain independent assessments of the vendors' data management processes, because this will provide an objective and reliable evaluation of the vendors' privacy practices, policies, and controls.
Independent assessments can be performed by external auditors, consultants, or certification bodies that have the expertise and credibility to verify the vendors' compliance with the contractual obligations and expectations. Independent assessments can also help identify and address any privacy risks or gaps that may arise from the vendors' processing of personal data12.
References:
* CDPSE Exam Content Outline, Domain 1 - Privacy Governance (Governance, Management & Risk Management), Task 7: Participate in the management and evaluation of contracts, service levels and practices of vendors and other external parties3.
* CDPSE Review Manual, Chapter 1 - Privacy Governance, Section 1.4 - Third-Party Management4.
NEW QUESTION # 69
Which of the following provides the BEST assurance that a potential vendor is able to comply with privacy regulations and the organization's data privacy policy?
- A. Requiring candidate vendors to provide documentation of privacy processes
- B. Including mandatory compliance language in the request for proposal (RFP)
- C. Obtaining self-attestations from all candidate vendors
- D. Conducting a risk assessment of all candidate vendors
Answer: D
Explanation:
Conducting a risk assessment of all candidate vendors is the best way to provide assurance that a potential vendor is able to comply with privacy regulations and the organization's data privacy policy, because it allows the organization to evaluate the vendor's privacy practices, controls, and performance against a set of criteria and standards. A risk assessment can also help to identify any gaps, weaknesses, or threats that may pose a risk to the organization's data privacy objectives and obligations. A risk assessment can be based on various sources of information, such as self-attestations, documentation, audits, or independent verification. A risk assessment can also help to prioritize the vendors based on their level of risk and impact, and to determine the appropriate mitigation or monitoring actions.
Reference:
8 Steps to Manage Vendor Data Privacy Compliance, DocuSign
Supplier Security and Privacy Assurance (SSPA) program, Microsoft Learn
NEW QUESTION # 70
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