Which of the following best describes ‘Processing’?
What are the two phases of DSCI Privacy Third Party Assessment?
Which of the following could be considered as triggers for updating privacy policy? (Choose all that apply.)
Categorise the following statement:
"For an identified data leakage scenario, security team is struggling to configure rules."
Which of the following is not an objective of VPI?
What is a Data Subject? (Choose all that apply.)
PPP
Based on the visibility exercise, the consultants created a single privacy policy applicable to all the client relationships and business functions. The policy detailed out what PI company deals with, how it is used, what security measures are deployed for protection, to whom it is shared, etc. Given the need to address all the client relationships and business functions, through a single policy, the privacy policy became very lengthy and complex. The privacy policy was published on company's intranet and also circulated to heads of all the relationships and functions. W.r.t some client relationships, there was also confusion whether the privacy policy should be notified to the end customers of the clients as the company was directly collecting PI as part of the delivery of BPM services. The heads found it difficult to understand the policy (as they could notdirectly relate to it) and what actions they need to perform. To assuage their concerns, a training workshop was conducted for 1 day. All the relationship and function heads attended the training. However, the training could not be completed in the given time, as there were numerous questions from the audiences and it took lot of time to clarify.
(Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion)
Introduction and Background
XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than 500 clients across industry verticals — BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.
The company is witnessing phenomenal growth in the BPM services over last few years including FinanceandAccounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company’s revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company’s attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects. The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).
To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens. The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.
Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.
What are key issues in the policy design process? (upto 250 words)
What is the maximum compensation that can be imposed on an organization for negligence in implementing reasonable security practices as defined in Section 43A of ITAA, 2008?
FILL BLANK
VPI
As a starting point, the consultants undertook a visibility exercise to understand the type of personal information (PI) being dealt with within the organization and also by third parties and the scope was to cover all the client relationships (IT services and BPM both) and functions. They met with the client relationship and business function owners to collect this data. The consultants did a mapping exercise to identify PI and associated attributes including whether company directly collects the PI, how it is accessed, transmitted, stored and what are the applicable regulatory and contractual requirements. Given the enormous scale of the exercise (enterprise wide), the consultant classified the PI as financial information, health related information, personally identifiable information, etc. and collected the rest of the attributes against this classification. When understanding the underlying technology environment, the consultants restricted themselves only to the technology environment that was under company’s ownership and premises and did not continue the exercise for client side environment. This was done because relationship owners seemed reluctant to share such client specific details. Only in 2 relationships, were the relationship heads proactive to introduce the consultants to the clients and get the requisite information. The analysis of the environment in these 2 relationships revealed that even though lots of restrictions were imposed at the company side, the same restrictions were not available at the client side.
Many business functions were also availing services from third party service providers. Though these functions were aware of the type of PI dealt by third parties, they were not aware of the technology environment at the third parties. In one odd case, personal information of a company employee was accidentally leaked by the employee of the third party through the social networking site. The consultants relied on whatever information was provided by the functions w.r.t. third parties. After finishing the data collection, the consultant used the information to create information flow maps highlighting the flow of information across systems deployed at the company premises. This work helped them have a high level view of PI dealt by the company. The data collection exercise has been conducted only once by the consultants. The visibility exercise empowered the management to have a company-wide view of PI and how it flows across the organization. This information was coupled with the security controls / practices deployed at the relationship or function level to derive the risk posture of the PI.
(Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion)
Introduction and Background
XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than 500 clients across industry verticals — BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.
The company is witnessing phenomenal growth in the BPM services over last few years including FinanceandAccounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company’s revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company’s attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects.
The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).
To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens. The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.
Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.
Was the visibility exercise adequately carried out? What gaps did you notice? (250 to 500 words)
Which of the following statements is true with respect to organization’s privacy training and awareness program?
