Free Practice Questions for Isaca CDPSE Exam

A data use policy is a document that defines the rules and guidelines for how personal data are collected, used, stored, shared and deleted by an organization. It is an important part of data governance and compliance, as it helps to ensure that personal data are handled in a lawful, fair and transparent manner, respecting the rights and preferences of data subjects. A data use policy should include the requirements for collecting and using personal data, such as the legal basis, the purpose, the scope, the consent, the data minimization, the accuracy, the security and the accountability. These requirements help to establish the legitimacy and necessity of data processing activities, and to prevent unauthorized or excessive use of personal data.

References:

ISACA Privacy Notice & Usage Disclosures, section 2.1: “We collect Personal Information from you when you provide it to us directly or through a third party who has assured us that they have obtained your consent.”

Chapter Privacy Policy - Singapore Chapter - ISACA, section 2: “We will collect your personal data in accordance with the PDPA either directly from you or your authorized representatives, and/or through our third party service providers.”

Data Minimization—A Practical Approach - ISACA, section 2: “Enterprises may only collect as much data as are necessary for the purposes defined at the time of collection, which may also be set out in a privacy notice (sometimes referred to as a privacy statement, a fair processing statement or a privacy policy).”

Establishing Enterprise Roles for Data Protection - ISACA, section 3: “Data governance is typically implemented in organizations through policies, guidelines, tools and access controls.”

A privacy impact assessment (PIA) is a systematic process to identify and evaluate the potential privacy impacts of a system, project, program or initiative that involves the collection, use, disclosure or retention of personal data. A PIA should be done first when planning a new implementation for tracking consumer web browser activity, as it would help to ensure that privacy risks are identified and mitigated before the implementation is executed. A PIA would also help to ensure compliance with privacy principles, laws and regulations, and alignment with consumer expectations and preferences. The other options are not as important as conducting a PIA when planning a new implementation for tracking consumer web browser activity. Seeking approval from regulatory authorities may be required or advisable for some types of personal data or data processing activities, but it may not be necessary or sufficient for tracking consumer web browser activity, depending on the context and jurisdiction. Obtaining consent from the organization’s clients may be required or advisable for some types of personal data or data processing activities, but it may not be necessary or sufficient for tracking consumer web browser activity, depending on the context and jurisdiction. Reviewing and updating the cookie policy may be required or advisable for some types of personal data or data processing activities, but it may not be necessary or sufficient for tracking consumer web browser activity, depending on the context and jurisdiction1, p. 67 References: 1: CDPSE Review Manual (Digital Version)

The most important consideration for determining the operational life of an encryption key is the volume and sensitivity of data protected by the key. The operational life of an encryption key is the period of time during which the key can be used securely and effectively to encrypt and decrypt data. The operational life of an encryption key depends on various factors, such as the length and complexity of the key, the strength and speed of the encryption algorithm, the number and frequency of encryption operations, the number of entities involved in communication, and the number of digitally signed documents in force. However, among these factors, the volume and sensitivity of data protected by the key is the most critical, as it affects the risk and impact of a potential compromise or exposure of the key. The higher the volume and sensitivity of data protected by the key, the shorter the operational life of the key should be, as this reduces the window of opportunity for an attacker to access or misuse the data.

References: CDPSE Review Manual, 2021, p. 117

Cloud vendor agreements are the best way to ensure an organization’s data retention requirements will be met in the public cloud environment because they define the roles, responsibilities and obligations of both parties regarding the collection, storage, processing and disposal of data in the cloud. They also specify the terms and conditions for data protection, security, privacy, compliance and auditability12. Data classification schemes, automated data deletion schedules and service level agreements (SLAs) are useful tools to manage and monitor data retention, but they do not guarantee that the cloud vendor will adhere to the organization’s data retention requirements or that they will be enforceable in case of disputes.

References: 1: CDPSE Review Manual (Digital Version), Domain 1: Privacy Governance, Task 1.7: Participate in the management and evaluation of contracts, service levels and practices of vendors and other external parties 2: CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 2: Privacy Governance, Section: Vendor Management

Input validation controls are the best way to ensure consumer credit card numbers are accurately captured. Input validation controls are methods that check the format, type, range, and length of the input data before accepting, processing, or storing it. Input validation controls can help prevent errors, fraud, or data loss by rejecting invalid, incomplete, or malicious input. For example, input validation controls can verify that a credit card number follows the Luhn algorithm1, has the correct number of digits2, and matches the card issuer’s prefix3. Input validation controls can also prevent SQL injection attacks4 or cross-site scripting attacks5 that may compromise the security and privacy of the data.

Input reference controls, access controls, and reconciliation controls are also important for data quality and security, but they do not directly ensure the accuracy of consumer credit card numbers. Input reference controls are methods that compare the input data with a predefined list of values or a reference table to ensure consistency and validity. For example, input reference controls can check if a country name or a postal code is valid by looking up a database of valid values. Access controls are methods that restrict who can access, modify, or delete the data based on their roles, permissions, or credentials. For example, access controls can prevent unauthorized users from accessing or tampering with consumer credit card numbers. Reconciliation controls are methods that compare the data from different sources or systems to ensure completeness and accuracy. For example, reconciliation controls can check if the transactions recorded in the accounting system match the transactions processed by the payment gateway.

References: Luhn algorithm, Credit card number, Bank card number, SQL injection, Cross-site scripting

The most important consideration when writing an organization’s privacy policy is to align the statements to the organizational practices, because this will help ensure that the policy is accurate, consistent, and transparent. A privacy policy is a document that explains how the organization collects, uses, discloses, and protects personal data from its customers, employees, partners, and other stakeholders. A privacy policy should reflect the actual data processing activities and privacy measures of the organization, as well as comply with the applicable laws and regulations. A privacy policy that is not aligned with the organizational practices may lead to confusion, mistrust, or legal liability12.

References:

CDPSE Review Manual, Chapter 1 – Privacy Governance, Section 1.2 – Privacy Policy3.

CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 1 – Privacy Governance, Section 1.2 – Data Privacy Laws and Regulations4.

The applicable privacy legislation needs to be identified first to define the privacy requirements to use when assessing the selection of IT systems, because it sets the legal obligations and standards for the organization to comply with when processing personal data. The type of data, the control frameworks, and the technology platforms are all dependent on the privacy legislation that applies to the organization and its data processing activities. Therefore, the privacy legislation is the primary source of privacy requirements for IT systems.

References:

CDPSE Review Manual, 2023 Edition, Domain 2: Privacy Architecture, Section 2.1.2: Privacy Requirements, p. 75

Compliance with Cybersecurity and Privacy Laws and Regulations1

The best way to address the concern that data collected by a third-party vendor and provided back to the organization may not be protected according to the organization’s privacy notice is to validate contract compliance. This means that the organization should verify that the third-party vendor is adhering to the terms and conditions of the contract, which should include clauses on data protection, privacy, and security. The contract should also specify the obligations and responsibilities of both parties regarding data collection, processing, storage, transfer, retention, and disposal. By validating contract compliance, the organization can ensure that the third-party vendor is following the same privacy standards and practices as the organization.

References:

ISACA, CDPSE Review Manual 2021, Chapter 2: Privacy Governance, Section 2.3: Third-Party Management, p. 51-52.

ISACA, Data Privacy Audit/Assurance Program, Control Objective 8: Third-Party Management, p. 14-151

Requiring independent audits of the providers’ data privacy controls is the best way to ensure third-party providers that process an organization’s personal data are addressed as part of the data privacy strategy. Independent audits can verify that the providers are complying with the applicable data privacy laws and regulations, as well as the organization’s own policies and standards. Independent audits can also identify any gaps or weaknesses in the providers’ data privacy controls and recommend corrective actions or improvements.

References:

What Is Your Privacy and Data Protection Strategy? - ISACA

Why data privacy and third-party risk teams need to work together - OneTrust