Certified Information Privacy Technologist Exam (CIPT) - IAPP Exam Questions

SCENARIO

Please use the following to answer the next question: Jordan just joined a fitness-tracker start-up based in California, USA, as its first Information Privacy and Security Officer. The company is quickly growing its business but does not sell any of the fitness trackers itself. Instead, it relies on a distribution network of third-party retailers in all major
countries. Despite not having any stores, the company has a 78% market share in the EU. It has a
website presenting the company and products, and a member section where customers can access their information. Only the email address and physical address need to be provided as part of the registration process in order to customize the site to the user’s region and country. There is also a newsletter sent every month to all members featuring fitness tips, nutrition advice, product spotlights from partner companies based on user behavior and preferences. Jordan says the General Data Protection Regulation (GDPR) does not apply to the company. He says the company is not established in the EU, nor does it have a processor in the region. Furthermore, it does not do any “offering goods or services” in the EU since it does not do any marketing there, nor sell to consumers directly. Jordan argues that it is the customers who chose to buy the products on their own initiative and there is no “offering” from the company. The fitness trackers incorporate advanced features such as sleep tracking, GPS tracking, heart rate monitoring. wireless syncing, calorie-counting and step-tracking. The watch must be paired with either a smartphone or a computer in order to collect data on sleep levels, heart rates, etc. All information from the device must be sent to the company’s servers in order to be processed, and then the results are sent to the smartphone or computer. Jordan argues that there is no personal information involved since the company does not collect banking or social security information. Based on the current features of the fitness watch, what would you recommend be implemented into each device in order to most effectively ensure privacy?

SCENARIO Wesley Energy has finally made its move, acquiring the venerable oil and gas exploration firm Lancelot from its long-time owner David Wilson. As a member of the transition team, you have come to realize that Wilson's quirky nature affected even Lancelot's data practices, which are maddeningly inconsistent. “The old man hired and fired IT people like he was changing his necktie,” one of Wilson’s seasoned lieutenants tells you, as you identify the traces of initiatives left half complete.
For instance, while some proprietary data and personal information on clients and employees is
encrypted, other sensitive information, including health information from surveillance testing of employees for toxic exposures, remains unencrypted, particularly when included within longer records with less-sensitive data. You also find that data is scattered across applications, servers and facilities in a manner that at first glance seems almost random.

Among your preliminary findings of the condition of data at Lancelot are the following: Cloud technology is supplied by vendors around the world, including firms that you have not heard of. You are told by a former Lancelot employee that these vendors operate with divergent security requirements and protocols. The company’s proprietary recovery process for shale oil is stored on servers among a variety of less- sensitive information that can be accessed not only by scientists, but by personnel of all types at most company locations. DES is the strongest encryption algorithm currently used for any file. Several company facilities lack physical security controls, beyond visitor check-in, which familiar vendors often bypass. Fixing all of this will take work, but first you need to grasp the scope of the mess and formulate a plan of action to address it.

Which is true regarding the type of encryption Lancelot uses?

SCENARIO Looking back at your first two years as the Director of Personal Information Protection and Compliance for the St. Anne’s Regional Medical Center in Thorn Bay, Ontario, Canada, you see a parade of accomplishments, from developing state-of-the-art simulation based training for employees on privacy protection to establishing an interactive medical records system that is accessible by patients as well as by the medical personnel. Now, however, a question you have put off looms large: how do we manage all the data-not only records produced recently, but those still on-hand from years ago? A data flow diagram generated last year shows multiple servers, databases, and work stations, many of which hold files that have not yet been incorporated into the new records system. While most of this data is encrypted, its persistence may pose security and compliance concerns. The situation is further complicated by several long-term studies being conducted by the medical staff using patient information. Having recently reviewed the major Canadian privacy regulations, you want to make certain that the medical center is observing them. You recall a recent visit to the Records Storage Section in the basement of the old hospital next to the modern facility, where you noticed paper records sitting in crates labeled by years, medical condition or alphabetically by patient name, while others were in undifferentiated bundles on shelves and on the floor. On the back shelves of the section sat data tapes and old hard drives that were often unlabeled but appeared to be years old. On your way out of the records storage section, you noticed a man leaving whom you did not recognize. He carried a batch of folders under his arm, apparently records he had removed from storage. You quickly realize that you need a plan of action on the maintenance, secure storage and disposal of data.

Which cryptographic standard would be most appropriate for protecting patient credit card information in the records system at St. Anne’s Regional Medical Center?

A valid argument against data minimization is that it?

SCENARIO WebTracker Limited is a cloud-based online marketing service located in London. Last year, WebTracker migrated its IT infrastructure to the cloud provider AmaZure, which provides SQL Databases and Artificial Intelligence services to WebTracker. The roles and responsibilities between the two companies have been formalized in a standard contract, which includes allocating the role of data controller to WebTracker. The CEO of WebTracker, Mr. Bond, would like to assess the effectiveness of AmaZure's privacy controls, and he recently decided to hire you as an independent auditor. The scope of the engagement is limited only to the marketing services provided by WebTracker, you will not be evaluating any internal data processing activity, such as HR or Payroll. This ad-hoc audit was triggered due to a future partnership between WebTracker and SmartHome — a partnership that will not require any data sharing. SmartHome is based in the USA, and most recently has dedicated substantial resources to developing smart refrigerators that can suggest the recommended daily calorie intake based on DNA information. This and other personal data is collected by WebTracker. To get an idea of the scope of work involved, you have decided to start reviewing the company's documentation and interviewing key staff to understand potential privacy risks.

The results of this initial work include the following notes: There are several typos in the current privacy notice of WebTracker, and you were not able to find the privacy notice for SmartHome. You were unable to identify all the sub-processors working for SmartHome. No subcontractor is indicated in the cloud agreement with AmaZure, which is responsible for the support and maintenance of the cloud infrastructure. There are data flows representing personal data being collected from the internal employees of WebTracker, including an interface from the HR system. Part of the DNA data collected by WebTracker was from employees, as this was a prototype approved by the CEO of WebTracker. All the WebTracker and SmartHome customers are based in USA and Canada.

Which of the following issues is most likely to require an investigation by the Chief Privacy Officer (CPO) of WebTracker?