Free Practice Questions for IAPP CIPM Exam

Obfuscation is not a main technical data control area. Obfuscation means hiding or disguising data or information to make it less intelligible or accessible. Obfuscation can be used as a security measure or a privacy-enhancing technique, but it is not a specific type of data control. The main technical data control areas are tokenization, encryption, access controls, and data minimization. Tokenization means replacing sensitive data with non-sensitive substitutes called tokens that have no intrinsic value. Encryption means transforming data into an unreadable format that can only be decrypted with a key. Access controls mean restricting who can access or modify data based on their roles, permissions, or authentication methods. Data minimization means collecting, storing, and processing only the minimum amount of data necessary for a specific purpose1, 2. References: CIPM - International Association of Privacy Professionals, Free CIPM Study Guide - International Association of Privacy Professionals

Evaluating operations, systems, and processes is best described as ‘auditing’, as it involves conducting a systematic and independent examination of the organization’s privacy practices and controls to verify their effectiveness and compliance. The other options are more related to other forms of monitoring, such as complaint handling, reporting, and third-party oversight. References: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 5: Monitor privacy program performance.

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 destruction4 References: 1: Data Retrievability: What Is It?; 2: Data Lifecycle Management | IBM; 3: What is Least Privilege? Definition & Examples; 4: Technical Security Controls: Encryption, Firewalls & More

 The statement that is true about the Data Protection Impact Assessment (DPIA) process as required under the General Data Protection Regulation (GDPR) is that the DPIA must include a description of the proposed processing operation and its purpose. According to Article 35(7) of the GDPR, a DPIA shall contain at least:

“a systematic description of the envisaged processing operations and the purposes of the processing”;

“an assessment of the necessity and proportionality of the processing operations in relation to the purposes”;

“an assessment of the risks to the rights and freedoms of data subjects”;

“the measures envisaged to address the risks”;

“safeguards”, “security measures”;

“mechanisms to ensure the protection of personal data”;

“to demonstrate compliance with this Regulation taking into account the rights and legitimate interests of data subjects and other persons concerned”5

Therefore, a DPIA must include a description of what data processing activities are planned and why they are needed as part of its content. This helps to provide a clear overview of the processing operation and its objectives as well as to assess its necessity and proportionality in relation to its purposes6 References: 5: [General Data Protection Regulation (GDPR) – Official Legal Text], Article 35(7); 6: Data protection impact assessments | ICO

A Data Protection Impact Assessment (DPIA) is a process to help identify and minimize the data protection risks of a project. Under the GDPR, a DPIA is required when the processing is likely to result in a high risk to the rights and freedoms of individuals, especially when using new technologies. The GDPR provides some examples of high-risk processing activities, such as systematic and extensive evaluation of personal aspects, large-scale processing of special categories of data, or systematic monitoring of public areas. The other options are more likely to require a DPIA than the online magazine using a mailing list to send a generic daily digest to marketing emails, as they involve more sensitive or intrusive types of processing. References:

[Data protection impact assessments | ICO]

[Art. 35 GDPR – Data protection impact assessment - GDPR.eu]

This answer is the best suggestion that Albert should make based on his observations regarding recent security incidents, as it can help to ensure that Treasure Box’s privacy program and practices are assessed and verified by an independent and objective party who has the necessary expertise, experience and credentials to evaluate the company’s compliance with the applicable laws, regulations, standards and best practices for data protection. Using a third-party auditor can also help to identify any gaps, weaknesses or risks that may have been overlooked or missed by the prior internal audits, and to recommend or implement any improvements or corrective actions. A third-party audit can also help to enhance the company’s reputation and trust among its customers, partners and stakeholders, as well as demonstrate its commitment and accountability for privacy protection.

This is an example of Privacy by Design (PbD), which is an approach to systems engineering that integrates privacy into the design and development of products, services, and processes from the outset7 PbD aims to ensure that privacy is embedded into the core functionality of any system or service, rather than being added as an afterthought or a trade-off. PbD is based on seven foundational principles: proactive not reactive; preventive not remedial; privacy as the default setting; privacy embedded into design; full functionality – positive-sum, not zero-sum; end-to-end security – full lifecycle protection; visibility and transparency – keep it open; and respect for user privacy – keep it user-centric8

The best way for IgNight to prepare its IT team to manage these kind of security events is to conduct tabletop exercises. Tabletop exercises are simulated scenarios that test the organization’s ability to respond to security incidents in a realistic and interactive way. Tabletop exercises typically involve:

A facilitator who guides the participants through the scenario and injects additional challenges or variables

A scenario that describes a plausible security incident based on real-world threats or past incidents

A set of objectives that define the expected outcomes and goals of the exercise

A set of questions that prompt the participants to discuss their roles, responsibilities, actions, decisions, and communications during the incident response process

A feedback mechanism that collects the participants’ opinions and suggestions on how to improve the incident response plan and capabilities

Tabletop exercises help an organization prepare for and deal with security incidents by:

Enhancing the awareness and skills of the IT team and other stakeholders involved in incident response

Identifying and addressing the gaps, weaknesses, and challenges in the incident response plan and process

Improving the coordination and collaboration among the IT team and other stakeholders during incident response

Evaluating and validating the effectiveness and efficiency of the incident response plan and process

Generating and implementing lessons learned and best practices for incident response

The other options are not as effective or useful as tabletop exercises for preparing the IT team to manage security events. Updating the data inventory is a good practice for maintaining an accurate and comprehensive record of the personal data that the organization collects, processes, stores, shares, or disposes of. However, it does not test or improve the organization’s incident response capabilities or readiness. IT security awareness training is a good practice for educating the IT team and other employees on the basic principles and practices of cybersecurity. However, it does not simulate or replicate the real-world situations and challenges that the IT team may face during security incidents. Sharing communications relating to scheduled maintenance is a good practice for informing the IT team and other stakeholders of the planned activities and potential impacts on the IT systems and infrastructure. However, it does not prepare the IT team for dealing with unplanned or unexpected security events that may require immediate and coordinated response. References: CISA Tabletop Exercise Packages; Cybersecurity Tabletop Exercise Examples, Best Practices, and Considerations; Six Tabletop Exercises to Help Prepare Your Cybersecurity Team

Comprehensive and Detailed Explanation:

A Business Continuity Plan (BCP) ensures that organizations can recover from disruptions and maintain essential functions. Major stakeholders from every critical area must be involved to coordinate an effective response.

Option A (Environmental impacts) is relevant for physical disaster recovery but not directly for a data breach.

Option B (Retraining employees) is important but does not justify integrating the incident into BCP.

Option D (Competitive advantage loss) is a consequence but not the primary reason for BCP integration.

Option C (Major stakeholders are involved from every critical area of the business) is the correct answer because a comprehensive response requires cross-functional collaboration, including IT, legal, HR, and compliance teams.

A privacy readiness assessment is not required during a data privacy diligence process for Merger & Acquisition (M&A) deals, as it is usually done before the deal to evaluate the privacy maturity and compliance level of the target organization. The other options are required during the data privacy diligence process to ensure that the personal data of both organizations are handled in accordance with the applicable laws and regulations, as well as the expectations of the data subjects and stakeholders. References: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 4: Manage data transfers.