Information classification of personal information may trigger specific regulatory obligations. Which statement is the BEST response from a privacy perspective:
Personally identifiable financial information includes only consumer report information
Public personal information includes only web or online identifiers
Personally identifiable information and personal data are similar in context, but may have different legal definitions based upon jurisdiction
Personally Identifiable Information and Protected Healthcare Information require the exact same data protection safequards
The Answer Is:
CExplanation:
Personal information is any information that can be used to identify an individual, either directly or indirectly, such as name, address, email, phone number, ID number, etc. Personal data is a term used in some jurisdictions, such as the European Union, to refer to personal information that is subject to data protection laws and regulations. However, the scope and definition of personal data may vary depending on the jurisdiction and the context. For example, the GDPR defines personal data as “any information relating to an identified or identifiable natural person” and includes online identifiers, such as IP addresses, cookies, or device IDs, as well as special categories of data, such as biometric, genetic, health, or political data. On the other hand, the US does not have a single federal law that regulates personal data, but rather a patchwork of sector-specific and state-level laws that may have different definitions and requirements. For example, the California Consumer Privacy Act (CCPA) defines personal information as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household” and excludes publicly available information from its scope. Therefore, from a privacy perspective, it is important to understand the different legal definitions and obligations that may apply to personal information or personal data depending on the jurisdiction and the context of the data processing activity. References:
GDPR personal data – what information does this cover?
Personal Information, Data Classification, Life Cycle and Best Practices
5 Types of Data Classification (With Examples)
The following statements reflect user obligations defined in end-user device policies
EXCEPT:
A statement specifying the owner of data on the end-user device
A statement that defines the process to remove all organizational data, settings and accounts alt offboarding
A statement detailing user responsibility in ensuring the security of the end-user device
A statement that specifies the ability to synchronize mobile device data with enterprise systems
The Answer Is:
DExplanation:
End-user device policies are policies that establish the rules and requirements for the use and management of devices that access organizational data, networks, and systems. These policies typically include user obligations that define the responsibilities and expectations of the users regarding the security, privacy, and compliance of the devices they use. According to the web search results from the search_web tool, some common user obligations defined in end-user device policies are:
A statement specifying the owner of data on the end-user device: This statement clarifies who owns the data stored on the device, whether it is the organization, the user, or a third party. This statement also defines the rights and obligations of the data owner and the data custodian, such as the access, retention, disposal, and protection of the data123.
A statement that defines the process to remove all organizational data, settings and accounts at offboarding: This statement outlines the steps and procedures that the user must follow to securely erase or transfer all organizational data, settings, and accounts from the device when they leave the organization or change their role. This statement also specifies the roles and responsibilities of the user, the organization, and the device manager in ensuring the proper offboarding of the device143.
A statement detailing user responsibility in ensuring the security of the end-user device: This statement describes the actions and measures that the user must take to protect the device from unauthorized access, theft, loss, damage, or compromise. This statement may include requirements such as enabling encryption, password, firewall, antivirus, updates, and backups, as well as reporting any incidents or issues related to the device1435.
However, option D, a statement that specifies the ability to synchronize mobile device data with enterprise systems, is not a user obligation defined in end-user device policies. Rather, this statement is a feature or functionality that may be enabled or disabled by the organization or the device manager, depending on the security and compliance needs of the organization. This statement may also be part of a device configuration policy or a mobile device management policy, which are different from end-user device policies. Therefore, option D is the correct answer, as it is the only one that does not reflect a user obligation defined in end-user device policies. References: The following resources support the verified answer and explanation:
1: End-User Device Policy | IT Services - University of Chicago
4: Device compliance policies in Microsoft Intune | Microsoft Learn
2: Basics of an End User Computing Policy - Apparity Blog
3: End-User Device Management Standard Operating Procedure
5: End-User Devices | Information Security - University of Chicago
Select the risk type that is defined as: “A third party may not be able to meet its obligations due to inadequate systems or processes”.
Reliability risk
Performance risk
Competency risk
Availability risk
The Answer Is:
BExplanation:
Performance risk, defined as the risk that a third party may not be able to meet its obligations due to inadequate systems or processes, accurately describes the situation. This type of risk involves concerns about the third party's ability to deliver services or products at the required performance level, potentially due to limitations in their technology infrastructure, operational procedures, or management practices. Identifying and managing performance risk is essential in Third-Party Risk Management (TPRM) to ensure that third-party vendors can reliably meet contractual and service-level agreements, thereby minimizing the impact on the organization's operations and service delivery.
References:
TPRM guidelines, such as those from the Office of the Comptroller of the Currency (OCC) and the Federal Financial Institutions Examination Council (FFIEC), highlight the importance of assessing and managing performance risks associated with third-party relationships.
The "Third-Party Risk Management Guide" by ISACA discusses various types of risks, including performance risk, associated with engaging third-party service providers, emphasizing the need for thorough due diligence and ongoing monitoring.
Which statement is FALSE regarding analyzing results from a vendor risk assessment?
The frequency for conducting a vendor reassessment is defined by regulatory obligations
Findings from a vendor risk assessment may be defined at the entity level, and are based o na Specific topic or control
Identifying findings from a vendor risk assessment can occur at any stage in the contract lifecycle
Risk assessment findings identified by controls testing or validation should map back to the information gathering questionnaire and agreed upon framework
The Answer Is:
AExplanation:
The frequency for conducting a vendor reassessment is not necessarily defined by regulatory obligations, but rather by the risk rating and criticality of the vendor, as well as the changes in the vendor’s environment, performance, and controls. Regulatory obligations may provide some guidance or minimum requirements for vendor reassessment, but they are not the sole determinant of the reassessment frequency. According to the Shared Assessments Program Tools User Guide, "The frequency of reassessment should be based on the risk rating and criticality of the vendor, as well as any changes in the vendor’s environment, performance, or controls. Regulatory guidance may also influence the frequency of reassessment."1 Similarly, the CTPRP Study Guide states, "The frequency of reassessment should be based on the risk rating and criticality of the vendor, as well as any changes in the vendor’s environment, performance, or controls. Regulatory guidance may also influence the frequency of reassessment."2
References:
Shared Assessments Program Tools User Guide
CTPRP Study Guide
Which statement is NOT an example of the purpose of internal communications and information sharing using TPRM performance metrics?
To communicate the status of findings identified in vendor assessments and escalate issues es needed
To communicate the status of policy compliance with TPRM onboarding, periodic assessment and off-boarding requirements
To document the agreed upon corrective action plan between external parties based on the severity of findings
To develop and provide periodic reporting to management based on TPRM results
The Answer Is:
CExplanation:
The purpose of internal communications and information sharing using TPRM performance metrics is to inform and align the organization’s stakeholders on the status, progress, and outcomes of the TPRM program. This includes communicating the results of vendor assessments, the compliance level of the organization’s policies and procedures, and the periodic reporting to management and other relevant parties. However, documenting the corrective action plan between external parties is not an internal communication, but rather an external one. This is because the corrective action plan is a formal agreement between the organization and the vendor to address and resolve the issues identified in the assessment. Therefore, this statement is not an example of the purpose of internal communications and information sharing using TPRM performance metrics. References:
15 KPIs & Metrics to Measure the Success of Your TPRM Program
Third-party risk management metrics: Best practices to enhance your program
3 Best Third-Party Risk Management Software Solutions (2024)
Which statement is NOT a method of securing web applications?
Ensure appropriate logging and review of access and events
Conduct periodic penetration tests
Adhere to web content accessibility guidelines
Include validation checks in SDLC for cross site scripting and SOL injections
The Answer Is:
CExplanation:
Web content accessibility guidelines (WCAG) are a set of standards that aim to make web content more accessible to people with disabilities, such as visual, auditory, cognitive, or motor impairments. While WCAG is a good practice for web development and usability, it is not directly related to web application security. WCAG does not address the common security risks that web applications face, such as injection, broken authentication, misconfiguration, or vulnerable components. Therefore, adhering to WCAG is not a method of securing web applications, unlike the other options. References:
4: OWASP Top 10, a standard awareness document for web application security, lists the most critical security risks to web applications and provides best practices to prevent or mitigate them.
5: SANS Institute, a leading provider of cybersecurity training and certification, offers a security checklist for web application technologies (SWAT) that covers best practices for error handling, data protection, configuration, authentication, session management, input and output handling, and access control.
6: Built In, a platform for tech professionals, provides 13 web application security best practices, such as using a web application firewall, keeping track of APIs, enforcing expected application behaviors, and following the OWASP Top 10.
A contract clause that enables each party to share the amount of information security risk is known as:
Limitation of liability
Cyber Insurance
Force majeure
Mutual indemnification
The Answer Is:
DExplanation:
Indemnification is a contractual obligation by which one party agrees to compensate another party for any losses or damages that may arise from a specified event or circumstance. Mutual indemnification means that both parties agree to indemnify each other for certain losses or damages, such as those caused by a breach of contract, negligence, or violation of law. Mutual indemnification can enable each party to share the amount of information security risk, as it can provide a mechanism for allocating the responsibility and liability for any security incidents or breaches that may affect either party or their customers. Mutual indemnification can also incentivize each party to maintain adequate security controls and practices, as well as to cooperate and communicate effectively in the event of a security incident or breach.
The other options are not contract clauses that enable each party to share the amount of information security risk, because:
A. Limitation of liability is a contract clause that limits the amount or type of damages that one party can claim from another party in the event of a breach of contract or other legal action. Limitation of liability does not enable each party to share the amount of information security risk, as it can reduce or cap the liability of one party, but not necessarily distribute or balance the risk between both parties.
B. Cyber insurance is a type of insurance policy that covers the costs and losses resulting from cyberattacks, data breaches, or other cyber incidents. Cyber insurance does not enable each party to share the amount of information security risk, as it can transfer or mitigate the risk to a third-party insurer, but not necessarily allocate or share the risk between both parties.
C. Force majeure is a contract clause that excuses one or both parties from performing their contractual obligations in the event of an unforeseen or unavoidable event or circumstance that is beyond their control, such as a natural disaster, war, or pandemic. Force majeure does not enable each party to share the amount of information security risk, as it can suspend or terminate the contract in the event of a force majeure event, but not necessarily distribute or balance the risk between both parties.
References:
Shared Assessments CTPRP Study Guide, page 62, section 5.2.2: Contractual Terms
Third-Party Risk Management: Vendor Contract Terms and Conditions, section: Indemnification
Cybersecurity risks from third party vendors: PwC, section: Contractual terms and conditions
[Third-Party Risk Management: The 3rd Party Ecosystem: How to Manage the Risk While Keeping the Benefit], section: Contractual Terms and Conditions
Which example of a response to external environmental factors is LEAST likely to be managed directly within the BCP or IT DR plan?
Protocols for social media channels and PR communication
Response to a natural or man-made disruption
Dependency on key employee or supplier issues
Response to a large scale illness or health outbreak
The Answer Is:
AExplanation:
A BCP or IT DR plan is a set of procedures and actions that an organization takes to ensure the continuity and recovery of its critical business functions and IT systems in the event of a disruption. A BCP or IT DR plan typically covers the following aspects12:
Identification and prioritization of critical business functions and IT systems
Assessment and mitigation of risks and threats to the organization
Allocation and mobilization of resources and personnel
Communication and coordination with internal and external stakeholders
Testing and updating of the plan
Among the four examples of a response to external environmental factors, protocols for social media channels and PR communication are the least likely to be managed directly within the BCP or IT DR plan. This is because social media and PR communication are not critical business functions or IT systems that need to be restored or maintained during a disruption. They are rather supplementary tools that can be used to inform and engage with the public, customers, partners, and media about the organization’s situation and actions3. Therefore, protocols for social media and PR communication are more likely to be part of a crisis communication plan, which is a separate but related document that outlines the strategies and tactics for communicating with various audiences during a crisis.
The other three examples are more likely to be managed directly within the BCP or IT DR plan, as they directly affect the organization’s ability to perform its critical business functions and IT systems. For instance, a response to a natural or man-made disruption would involve activating the BCP or IT DR plan, assessing the impact and extent of the damage, deploying backup and recovery solutions, and restoring normal operations as soon as possible. A response to a dependency on key employee or supplier issues would involve identifying and managing the single points of failure, implementing contingency plans, and ensuring the availability and redundancy of essential skills and resources. A response to a large scale illness or health outbreak would involve implementing health and safety measures, enabling remote work arrangements, and ensuring the resilience and continuity of the workforce. References:
Business continuity vs. disaster recovery: Which plan is right … - IBM
Business Continuity vs Disaster Recovery: What’s The Difference?
Disaster recovery plan vs. business continuity plan: Is there a difference?
[Crisis Communication Plan: A PR Blue Print by Sandra K. Clawson Freeo]
[Disaster Recovery Planning (DRP) | Business Continuity Plan (BCP) | Disaster Recovery Journal]
[Managing Third Party Risk in a Disrupted World]
[Business Continuity Planning for a Pandemic]
Which of the following is NOT a key component of TPRM requirements in the software development life cycle (SDLC)?
Maintenance of artifacts that provide proof that SOLC gates are executed
Process for data destruction and disposal
Software security testing
Process for fixing security defects
The Answer Is:
BExplanation:
In the context of Third-Party Risk Management (TPRM) requirements within the Software Development Life Cycle (SDLC), a process for data destruction and disposal is not typically considered a key component. The primary focus within SDLC in TPRM is on ensuring secure software development practices, which includes maintaining artifacts to prove that SDLC gates are executed, conducting software security testing, and having processes in place for fixing security defects. While data destruction and disposal are important security considerations, they are generally associated with data lifecycle management and information security management practices rather than being integral to the SDLC process itself.
References:
Best practices in secure software development, as outlined in frameworks like the Secure Software Development Framework (SSDF) by NIST, emphasize the importance of secure coding, vulnerability testing, and remediation processes rather than data disposal practices.
The "Software Security Framework (SSF)" by the Open Web Application Security Project (OWASP) provides guidance on integrating security practices into the SDLC, focusing on areas like threat modeling, secure coding, and security testing.
Which action statement BEST describes an assessor calculating residual risk?
The assessor adjusts the vendor risk rating prior to reporting the findings to the business unit
The assessor adjusts the vendor risk rating based on changes to the risk level after analyzing the findings and mitigating controls
The business unit closes out the finding prior to the assessor submitting the final report
The assessor recommends implementing continuous monitoring for the next 18 months
The Answer Is:
BExplanation:
When calculating residual risk, the best practice for an assessor is to adjust the vendor risk rating based on the changes to the risk level after analyzing the findings and considering the effectiveness of mitigating controls. Residual risk refers to the level of risk that remains after controls are applied to mitigate the initial (inherent) risk. By evaluating the findings from a third-party assessment and factoring in the mitigating controls implemented by the vendor, the assessor can more accurately determine the remaining risk level. This adjusted risk rating provides a more realistic view of the vendor's risk profile, aiding in informed decision-making regarding risk management and vendor oversight.
References:
The concept of residual risk calculation is discussed in risk management frameworks such as ISO 31000 (Risk Management - Guidelines), which guides the assessment and treatment of risks.
The "Third-Party Risk Management Guide" by ISACA outlines the process of assessing and managing risks associated with third parties, including the calculation of residual risk.