Important IAPP CIPT Exam Questions

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?

SCENARIO

Carol was a U.S.-based glassmaker who sold her work at art festivals. She kept things simple by only accepting cash and personal checks.

As business grew, Carol couldn't keep up with demand, and traveling to festivals became burdensome. Carol opened a small boutique and hired Sam to run it while she worked in the studio. Sam was a natural salesperson, and business doubled. Carol told Sam, ''I don't know what you are doing, but keep doing it!"

But months later, the gift shop was in chaos. Carol realized that Sam needed help so she hired Jane, who had business expertise and could handle the back-office tasks. Sam would continue to focus on sales. Carol gave Jane a few weeks to get acquainted with the artisan craft business, and then scheduled a meeting for the three of them to discuss Jane's first impressions.

At the meeting, Carol could not wait to hear Jane's thoughts, but she was unprepared for what Jane had to say. ''Carol, I know that he doesn't realize it, but some of Sam's efforts to increase sales have put you in a vulnerable position. You are not protecting customers' personal information like you should.''

Sam said, ''I am protecting our information. I keep it in the safe with our bank deposit. It's only a list of customers' names, addresses and phone numbers that I get from their checks before I deposit them. I contact them when you finish a piece that I think they would like. That's the only information I have! The only other thing I do is post photos and information about your work on the photo sharing site that I use with family and friends. I provide my email address and people send me their information if they want to see more of your work. Posting online really helps sales, Carol. In fact, the only complaint I hear is about having to come into the shop to make a purchase.''

Carol replied, ''Jane, that doesn't sound so bad. Could you just fix things and help us to post even more online?"

'I can," said Jane. ''But it's not quite that simple. I need to set up a new program to make sure that we follow the best practices in data management. And I am concerned for our customers. They should be able to manage how we use their personal information. We also should develop a social media strategy.''

Sam and Jane worked hard during the following year. One of the decisions they made was to contract with an outside vendor to manage online sales. At the end of the year, Carol shared some exciting news. ''Sam and Jane, you have done such a great job that one of the biggest names in the glass business wants to buy us out! And Jane, they want to talk to you about merging all of our customer and vendor information with theirs beforehand."

When initially collecting personal information from customers, what should Jane be guided by?

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.

Based on the initial assessment and review of the available data flows, which of the following would be the most important privacy risk you should investigate first?

When analyzing user data, how is differential privacy applied?

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?