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Which of the following would be the best method of ensuring that Information Technology projects follow Privacy by Design (PbD) principles?
Privacy by Design (PbD) Integration: Ensuring that IT projects follow PbD principles requires a comprehensive approach embedded throughout the development lifecycle.
Technical Privacy Framework: Developing a technical privacy framework that integrates with the development lifecycle is crucial. This framework provides structured guidance and tools for implementing privacy controls and processes from the initial design to the final deployment.
Lifecycle Integration: By integrating privacy into every phase of the development lifecycle (requirements, design, implementation, testing, and maintenance), privacy concerns are addressed proactively rather than reactively.
Reference: The IAPP documentation on Privacy by Design emphasizes the importance of integrating privacy into the system development lifecycle to ensure ongoing and consistent protection of personal data.
Which of the following suggests the greatest degree of transparency?
The option that suggests the greatest degree of transparency is After reading the privacy notice, a data subject confidently infers how her information will be used. Transparency in data protection means that data subjects should have clear, concise, and understandable information about how their data is collected, used, and shared. The ability of the data subject to confidently infer the use of their information after reading the privacy notice indicates that the notice is clear and transparent, effectively communicating the data processing practices.
GDPR, Article 12: Transparent information, communication, and modalities for the exercise of the rights of the data subject
'Privacy on the Ground: Driving Corporate Behavior' by Kenneth A. Bamberger and Deirdre K. Mulligan
Organizations understand there are aggregation risks associated with the way the process their customer's data. They typically include the details of this aggregation risk in a privacy notice and ask that all customers acknowledge they understand these risks and consent to the processing.
What type of risk response does this notice and consent represent?
Option A: Risk transfer involves shifting the risk to another party, such as through insurance. Simply informing customers does not transfer the risk.
Option B: Risk mitigation involves taking steps to reduce the severity or likelihood of the risk. Informing and obtaining consent does not mitigate the risk but acknowledges it.
Option C: Risk avoidance involves changing plans to entirely avoid the risk. Informing customers of the risk is not avoiding it but rather acknowledging it.
Option D: Risk acceptance involves recognizing the risk and deciding to proceed with it. By informing customers and obtaining their consent, the organization acknowledges the risk and accepts it as part of their operations.
IAPP CIPT Study Guide
Risk management frameworks and practices in privacy
What is typically NOT performed by sophisticated Access Management (AM) techniques?
Sophisticated Access Management (AM) techniques focus on controlling who can access certain data and under what conditions. Techniques such as restricting access based on location (A), user role (B), and device type (C) are common in access management systems. However, preventing data from being placed in unprotected storage (D) falls more under data security and protection measures rather than access management. AM primarily addresses the question of who has access and how, whereas ensuring that data is stored securely involves encryption, secure storage solutions, and proper configuration management, which are typically beyond the scope of AM systems. This distinction is made clear in various security and privacy guidelines, including those provided by the IAPP and the National Institute of Standards and Technology (NIST).
SCENARIO
Clean-Q is a company that offers house-hold and office cleaning services. The company receives requests from consumers via their website and telephone, to book cleaning services. Based on the type and size of service, Clean-Q then contracts individuals that are registered on its resource database - currently managed in-house by Clean-Q IT Support. Because of Clean-Q's business model, resources are contracted as needed instead of permanently employed.
The table below indicates some of the personal information Clean-Q requires as part of its business operations:
Clean-Q has an internal employee base of about 30 people. A recent privacy compliance exercise has been conducted to align employee data management and human resource functions with applicable data protection regulation. Therefore, the Clean-Q permanent employee base is not included as part of this scenario.
With an increase in construction work and housing developments, Clean-Q has had an influx of requests for cleaning services. The demand has overwhelmed Clean-Q's traditional supply and demand system that has caused some overlapping bookings.
Ina business strategy session held by senior management recently, Clear-Q invited vendors to present potential solutions to their current operational issues. These vendors included Application developers and Cloud-Q's solution providers, presenting their proposed solutions and platforms.
The Managing Director opted to initiate the process to integrate Clean-Q's operations with a cloud solution (LeadOps) that will provide the following solution one single online platform: A web interface that Clean-Q accesses for the purposes of resource and customer management. This would entail uploading resource and customer information.
A customer facing web interface that enables customers to register, manage and submit cleaning service requests online.
A resource facing web interface that enables resources to apply and manage their assigned jobs.
An online payment facility for customers to pay for services.
What is a key consideration for assessing external service providers like LeadOps, which will conduct personal information processing operations on Clean-Q's behalf?
A key consideration for assessing external service providers like LeadOps, which will conduct personal information processing operations on Clean-Q's behalf, is obtaining knowledge of LeadOps' information handling practices and information security environment.
Due Diligence: Evaluating LeadOps' data handling practices ensures that they follow robust data protection principles, including data minimization, purpose limitation, and data retention policies.
Security Measures: Understanding their information security environment involves assessing technical and organizational measures in place to protect personal data. This includes encryption, access controls, incident response plans, and regular security audits.
Compliance and Certification: Verifying compliance with recognized standards such as ISO/IEC 27001 can provide assurance that LeadOps follows best practices in information security management.
Privacy Impact Assessments (PIAs): Conducting a PIA can help identify and mitigate privacy risks associated with outsourcing to LeadOps. It involves evaluating the potential impact on data subjects and implementing appropriate controls to protect their data.
Contractual Safeguards: Ensuring that contracts with LeadOps include specific data protection clauses, such as data processing agreements (DPAs), to delineate responsibilities and ensure compliance with data protection laws.
IAPP Privacy Management, Information Privacy Technologist Certification Textbooks
ISO/IEC 27001 -- Information Security Management Systems
GDPR Article 28 -- Processor
