CIPM Exam: Absolutely Free Online Practice

Free IAPP CIPM Exam Questions

Please use the following to answer the next question:

You lead the privacy office for a company that handles information from individuals living in several countries

throughout Europe and the Americas. You begin that morning’s privacy review when a contracts officer sends

you a message asking for a phone call. The message lacks clarity and detail, but you presume that data was

lost.

When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating

that the vendor improperly shared information about your customers. He called the vendor and confirmed that

your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and

sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database

as promised in the contract. As a result, the vendor has lost control of the data.

The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell

you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the

mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write.

You put their offer on hold and begin to develop the text around the space constraints. You are content to let

the vendor’s logo be associated with the notification.

The notification explains that your company recently hired a vendor to store information about their most recent

experience at St. Sebastian Hospital’s Clinic for Infectious Diseases. The vendor did not encrypt the information

and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about

their information. They simply need to go to your company’s website and watch a quick advertisement, then

provide their name, email address, and month and year of birth.

You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation,

you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their

comments back and forth. The consultant who leads the incident-response team notes that it is his first day with

the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on

the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the

day, they vote to proceed with the notification you wrote and use the vendor’s postcards.

Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the

decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring

company with a convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled

a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:

1. Send an enrollment invitation to everyone the day after the contract is signed.

2. Enroll someone with just their first name and the last-4 of their national identifier.

3. Monitor each enrollee’s credit for two years from the date of enrollment.

4. Send a monthly email with their credit rating and offers for credit-related services at market rates.

5. Charge your company 20% of the cost of any credit restoration.

You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three days later

you sit down and document all that went well and all that could have gone better. You put it in a file to reference

the next time an incident occurs.

Regarding the credit monitoring, which of the following would be the greatest concern?

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

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

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

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

departments to interpret the privacy policy differently?

Free IAPP CIPM Exam Questions

Absolute Free CIPM Exam Practice for Comprehensive Preparation