Question 1

When conducting due diligence during an acquisition, what should a privacy professional avoid?

Options :

A : Discussing with the acquired company the type and scope of their data processing.

B : Allowing legal in both companies to handle the privacy laws and compliance.

C : Planning for impacts on the data processing operations post-acquisition.

D : Benchmarking the two companies’ privacy policies against one another.

Answer: B

Question 2

What is the key factor that lays the foundation for all other elements of a privacy program?

Options :

A : The applicable privacy regulations

B : The structure of a privacy team

C : A privacy mission statement

D : A responsible internal stakeholder

Answer: C

Question 3

When devising effective employee policies to address a particular issue, which of the following should be included in the first draft?

Options :

A : Rationale for the policy.

B : Points of contact for the employee.

C : Roles and responsibilities of the different groups of individuals.

D : Explanation of how the policy is applied within the organization.

Answer: A

Question 4

SCENARIO

Please use the following to answer the next question:

Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the

development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can

be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After

having had a successful launch in the United States, the Handy Helper is about to be made available for

purchase worldwide.

The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the

whole family, including children, but does not provide any further detail or privacy notice. In order to use the

application, a family creates a single account, and the primary user has access to all information about the

other users. Upon start up, the primary user must check a box consenting to receive marketing emails from

Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.

Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European

distributor of Handy Helper when he fielded many questions about the product from the distributor. Sanjay

needed to look more closely at the product in order to be able to answer the questions as he was not involved

in the product development process.

In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's

sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is

stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the

product. This data is all stored in the cloud and is encrypted both during transmission and at rest.

Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent

Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is

hoping that at some point in the future, the data will reveal insights that could be used to create a fully

automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is

considered a long-term goal.

What administrative safeguards should be implemented to protect the collected data while in use by Manasa

and her product management team?

Options :

A : Document the data flows for the collected data

B : Conduct a Privacy Impact Assessment (PIA) to evaluate the risks involved.

C : Implement a policy restricting data access on a "need to know" basis.

D : Limit data transfers to the US by keeping data collected in Europe within a local data center.

Answer: C

Question 5

SCENARIO

Please use the following to answer the next question:

Amira is thrilled about the sudden expansion of NatGen. As the joint Chief Executive Officer (CEO) with her

long-time business partner Sadie, Amira has watched the company grow into a major competitor in the green

energy market. The current line of products includes wind turbines, solar energy panels, and equipment for

geothermal systems. A talented team of developers means that NatGen's line of products will only continue to

grow.

With the expansion, Amira and Sadie have received advice from new senior staff members brought on to help

manage the company's growth. One recent suggestion has been to combine the legal and security functions of

the company to ensure observance of privacy laws and the company's own privacy policy. This sounds overly

complicated to Amira, who wants departments to be able to use, collect, store, and dispose of customer data in

ways that will best suit their needs. She does not want administrative oversight and complex structuring to get

in the way of people doing innovative work.

Sadie has a similar outlook. The new Chief Information Officer (CIO) has proposed what Sadie believes is an

unnecessarily long timetable for designing a new privacy program. She has assured him that NatGen will use

the best possible equipment for electronic storage of customer and employee data. She simply needs a list of

equipment and an estimate of its cost. But the CIO insists that many issues are necessary to consider before

the company gets to that stage.

Regardless, Sadie and Amira insist on giving employees space to do their jobs. Both CEOs want to entrust the

monitoring of employee policy compliance to low-level managers. Amira and Sadie believe these managers can

adjust the company privacy policy according to what works best for their particular departments. NatGen's

CEOs know that flexible interpretations of the privacy policy in the name of promoting green energy would be

highly unlikely to raise any concerns with their customer base, as long as the data is always used in course of

normal business activities.

Perhaps what has been most perplexing to Sadie and Amira has been the CIO's recommendation to institute a

privacy compliance hotline. Sadie and Amira have relented on this point, but they hope to compromise by

allowing employees to take turns handling reports of privacy policy violations. The implementation will be easy

because the employees need no special preparation. They will simply have to document any concerns they

hear.

Sadie and Amira are aware that it will be challenging to stay true to their principles and guard against corporate

culture strangling creativity and employee morale. They hope that all senior staff will see the benefit of trying a

unique approach.

What Data Lifecycle Management (DLM) principle should the company follow if they end up allowing

departments to interpret the privacy policy differently?

Options :

A : Prove the authenticity of the company-s records.

B : Arrange for official credentials for staff members

C : Adequately document reasons for inconsistencies

D : Create categories to reflect degrees of data importance.

Answer: C

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