Free Practice Questions for IAPP CIPP-C Exam

The Government of Canada’s Directive on Privacy Impact Assessments is designed to ensure that privacy implications are appropriately considered in the delivery of Government of Canada programs and services. This directive typically applies to federal departments and agencies. However, it does not apply to The Cabinet, which is essentially part of the executive branch of government involved in decision-making at the highest levels. Cabinet discussions and materials are often confidential and governed by different sets of rules regarding privacy and security. Thus, the correct answer is D, The Cabinet.

In Ontario, the handling of personal information in the context of Freedom of Information (FOI) requests is governed by the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) for municipalities, or the Freedom of Information and Protection of Privacy Act (FIPPA) for provincial institutions, including hospitals. These acts typically allow for the disclosure of employment-related information, such as employee name, title, and designation, as this information is considered related to the individual's professional role rather than their personal life. Employee personal cell phone numbers and feedback about the employee from a colleague, however, are considered personal information and are generally protected from disclosure. Therefore, the statement "Employee name, title, and designation can be released as it is not classified as personal information" (Option C) is accurate.

Under the Privacy Act, a request for access to one’s personal information can be denied in specific circumstances, such as when the information was collected by the Royal Canadian Mounted Police (RCMP) while performing policing services for a province or municipality. This scenario typically involves information collected for law enforcement, investigation, or security purposes, where releasing it might compromise ongoing operations or the methods used in such operations. The Privacy Act includes provisions to deny access when disclosure could reasonably be expected to prejudice the enforcement of laws, the conduct of investigations, or similar matters related to law enforcement and security.

When a financial institution such as a bank or an investment advisor collects a social insurance number (SIN) for tax reporting purposes, especially in contexts like opening a Registered Retirement Savings Plan (RRSP), it is mandatory because the SIN is required by law for such purposes. However, the use of the SIN for other purposes, such as identity verification, is not mandatory and should only be done with the client's consent. Thus, the correct answer is A, "Optional for identity verification purposes," indicating that while the SIN is necessary for tax purposes, its use for verifying identity is at the client's discretion.

Alberta's Health Information Act (HIA) is not considered substantially similar to the Personal Information Protection and Electronic Documents Act (PIPEDA). While the HIA governs the collection, use, and disclosure of health information specifically within Alberta, it is structured differently and has distinct provisions compared to PIPEDA, which is a federal privacy law applicable to the private sector across all provinces and territories in Canada, except for those areas where provincial privacy laws have been deemed substantially similar. The other provincial acts listed (from New Brunswick, Ontario, and Nova Scotia) are recognized by the federal government as being substantially similar to PIPEDA, meaning they provide similar protections and can supersede PIPEDA within their respective jurisdictions for the handling of health information.

The Office of the Privacy Commissioner of Canada’s (OPC) four-point test for determining the necessity and reasonableness of collecting, using, or disclosing personal information does not include questioning the validity and accuracy of the information as a direct component. The four-point test includes examining whether the measure is necessary to meet a specific need; whether it is likely to be effective in meeting that need; whether the loss of privacy is proportional to the benefit gained; and whether there are less privacy-invasive ways to achieve the same end. Therefore, option C, "Are the validity and accuracy of individual test results guaranteed to be accurate?" is not part of this test, as it concerns the technical and scientific reliability of the tests rather than the privacy implications of accessing or sharing the results.

When an organization responsible for a large number of records considers outsourcing the storage of those records, it is critical to ensure that there is a robust contractual agreement in place between the organization and the records storage company. This agreement should outline the responsibilities of the storage company, the security measures they must adhere to, and the conditions under which they handle the personal information stored on the records1.

A contractual agreement serves several important purposes:

It defines the scope of services provided by the storage company.

It sets forth the security standards and privacy protections that must be maintained.

It establishes the legal obligations of the storage company, including compliance with relevant privacy laws and regulations.

It provides a mechanism for accountability and recourse in the event of a breach or non-compliance.

While determining if the personal information will be used for data matching (option A) and ensuring that consent was informed and meaningful (option D) are important considerations, they do not directly address the relationship between the organization and the storage company. Conducting a Privacy Impact Assessment (PIA) (option C) is also a valuable step, but it is a preparatory measure that should inform the development of the contractual agreement rather than being the critical factor in the outsourcing decision.

Therefore, the verified answer is B, as establishing a contractual agreement is the most critical consideration to ensure that the outsourced storage of records is managed in a way that protects the personal information and complies with privacy laws and regulations

Under Canada’s Anti-Spam Legislation (CASL), proving compliance often revolves around demonstrating that valid consent (either express or implied) was obtained before sending commercial electronic messages. Keeping detailed records of how and when consent was obtained from recipients is crucial to demonstrate compliance if questioned by regulators or in the event of a complaint. This practice not only helps businesses defend their messaging practices but also aligns with the requirements of CASL to maintain evidence of consent. Hence, the correct answer is B, "Keeping records of express and implied consent of commercial electronic messages."

The key difference between the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Personal Information Privacy Act (PIPA) of both Alberta and British Columbia is the scope of their application. PIPEDA applies to federal undertakings and to organizations that engage in commercial activities across provincial or national borders, thus under federal jurisdiction. In contrast, PIPA legislation in Alberta and British Columbia applies only to private organizations within those provinces, covering most commercial activities that do not cross provincial boundaries unless otherwise covered under federal law. This distinction highlights the division of legislative powers between federal and provincial levels concerning privacy regulation in Canada.

Before implementing an electronic service (e-service), a federal government department is required to complete a Privacy Impact Assessment (PIA) in accordance with Treasury Board guidelines. A PIA is a process that helps federal institutions to evaluate how new or substantially modified programs or services could affect individual privacy and to address those effects appropriately. The guidelines provided by the Treasury Board specify how PIAs should be conducted to ensure that all privacy risks are identified and mitigated before the implementation of a new or modified e-service. This requirement is crucial for maintaining the privacy and security of personal information handled by government departments.