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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.
If Clean-Q were to utilize LeadOps' services, what is a contract clause that may be included in the agreement entered into with LeadOps?
When engaging with a cloud service provider like LeadOps, it's critical to include specific clauses in the contract to ensure the protection and management of personal information. Here's why a notification clause is essential:
Data Breach Notification: A provision requiring LeadOps to notify Clean-Q of any suspected breaches ensures that Clean-Q can take immediate action to mitigate any potential damage, inform affected individuals, and comply with regulatory obligations.
Regulatory Compliance: Many data protection regulations, such as GDPR and CCPA, mandate timely notification of data breaches to both the regulatory authorities and the affected individuals. Including this clause ensures compliance with such laws.
Risk Management: Prompt notification allows Clean-Q to manage and address any risks associated with the breach, including public relations issues and potential legal liabilities.
Transparency and Accountability: This clause promotes transparency and accountability, ensuring that LeadOps maintains a high standard of data security and is responsible for informing Clean-Q about any security incidents.
What must be done to destroy data stored on "write once read many" (WORM) media?
To destroy data stored on 'write once read many' (WORM) media, the media must be physically destroyed. WORM media is designed to prevent data from being modified or erased once written. Therefore, the only effective method to ensure that the data is irretrievable is to physically destroy the media.
IAPP CIPT Study Guide: Data destruction methods for various storage media.
NIST SP 800-88: Guidelines for Media Sanitization, which recommends physical destruction for WORM media.
What privacy risk is NOT mitigated by the use of encrypted computation to target and serve online ads?
Option A: Encrypted computation focuses on protecting the privacy of data while allowing computations to be performed on it. It does not address the relevance of ads to users, which is a separate issue related to the effectiveness of the ad targeting algorithm.
Option B: Encrypted computation aims to protect the user's sensitive personal information by ensuring it remains encrypted during the computation process, thus mitigating this privacy risk.
Option C: Encrypted computation prevents the server from discerning personal information as the data remains encrypted throughout the process.
Option D: By maintaining encryption, encrypted computation also helps prevent information leaks due to weak de-identification techniques.
IAPP CIPT Study Guide
Research papers on encrypted computation and privacy-preserving ad targeting
These detailed explanations provide context and references to ensure the answers align with the IAPP Information Privacy Technologist documents and best practices.
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?
Option A (Symmetric Encryption): Symmetric encryption uses the same key for both encryption and decryption. While effective for protecting data in transit or at rest, it does not address tokenization's specific use case for payment information.
Option B (Tokenization): Tokenization replaces sensitive data with non-sensitive tokens that can be used within the system without exposing actual credit card details. It is particularly effective for protecting payment information by reducing the risk of data breaches.
Option C (Obfuscation): Obfuscation is a technique to make data harder to understand but does not provide the strong security guarantees needed for protecting credit card information.
Option D (Certificates): Certificates are used in public key infrastructure (PKI) to authenticate identities and secure communications. They are not specifically used for protecting stored credit card information.
PCI DSS requirements for tokenization and data security.
NIST Special Publication 800-57 on Cryptographic Key Management.
Conclusion: Tokenization (Option B) is the most appropriate cryptographic standard for protecting patient credit card information, as it replaces sensitive data with tokens, reducing the risk of exposure.
An organization is using new technologies that will target and process personal data of EU customers. In which of the following circumstances would a privacy technologist need to support a data protection impact assessment (DPIA)?
A privacy technologist needs to support a Data Protection Impact Assessment (DPIA) if data processing is a high risk to an individual's rights and freedoms. DPIAs are mandatory under the General Data Protection Regulation (GDPR) when new technologies are used in ways that may significantly affect the privacy of EU customers. This ensures that potential privacy risks are identified and mitigated before data processing begins. The IAPP's CIPT resources emphasize the importance of DPIAs in managing high-risk data processing activities.
