CDPSE Exam Dumps - Certified Data Privacy Solutions Engineer

The best way for an organization to ensure its vendors are complying with data privacy requirements defined in their contracts is to obtain independent assessments of the vendors’ data management processes, because this will provide an objective and reliable evaluation of the vendors’ privacy practices, policies, and controls. Independent assessments can be performed by external auditors, consultants, or certification bodies that have the expertise and credibility to verify the vendors’ compliance with the contractual obligations and expectations. Independent assessments can also help identify and address any privacy risks or gaps that may arise from the vendors’ processing of personal data12.

The first step for an IT privacy practitioner following a decision to expand remote working capability is to evaluate the impact resulting from this change on the organization’s privacy policies, programs and practices. This will help identify the risks and gaps that need to be addressed, as well as the opportunities for improvement and optimization. The other options are possible actions that may be taken after the impact assessment, depending on the results and recommendations.

A data dictionary is a document that defines and describes the data elements, attributes, formats, sources, destinations, purposes and relationships of a data set or system. A data dictionary would be the best way to ensure personal data usage is standardized across the entire organization, as it would provide a common and consistent understanding and reference for how personal data is collected, used, disclosed and transferred within and outside the organization. A data dictionary would also help to ensure compliance with privacy principles, such as accuracy, transparency and accountability. The other options are not as effective as developing a data dictionary in ensuring personal data usage is standardized across the entire organization. De-identify all data is a technique that removes or modifies direct and indirect identifiers in a data set to prevent or limit the identification of the data subjects, but it does not ensure standardization or consistency of personal data usage across the organization. Encrypt all sensitive data is a technique that transforms plain text data into cipher text using an algorithm and a key, making it unreadable by unauthorized parties, but it does not ensure standardization or consistency of personal data usage across the organization. Perform data discovery is a process of identifying and locating personal data within an organization’s systems, databases, applications or files, but it does not ensure standardization or consistency of personal data usage across the organization1, p. 69-70 References: 1: CDPSE Review Manual (Digital Version)

After a privacy risk has been accepted, the next step is to monitor the risk landscape for material changes. This means that the organization should keep track of any internal or external factors that may affect the likelihood or impact of the risk, such as new threats, vulnerabilities, regulations, technologies, or business processes. Monitoring the risk landscape can help the organization identify if the risk acceptance decision is still valid, or if it needs to be revisited or revised. Monitoring can also help the organization prepare for potential incidents or consequences that may arise from the accepted risk.

The applicable privacy legislation needs to be identified first to define the privacy requirements to use when assessing the selection of IT systems, because it sets the legal obligations and standards for the organization to comply with when processing personal data. The type of data, the control frameworks, and the technology platforms are all dependent on the privacy legislation that applies to the organization and its data processing activities. Therefore, the privacy legislation is the primary source of privacy requirements for IT systems.

From a privacy perspective, it is most important to ensure data backups are encrypted. Encryption is a process of transforming data into an unreadable form using a secret key or algorithm. Encryption can help protect the confidentiality, integrity, and availability of data backups by preventing unauthorized access, disclosure, or modification. Encryption can also help comply with legal and regulatory requirements for data protection, such as the General Data Protection Regulation (GDPR) or the Health Insurance Portability and Accountability Act (HIPAA). Encryption can be applied to data backups at different levels, such as file-level, disk-level, or network-level encryption.

Incremental backups, differential backups, or pseudonymization are also useful for data backup management, but they are not the most important from a privacy perspective. Incremental backups are backups that only copy the data that has changed since the last backup, whether it was a full, differential, or incremental backup. Incremental backups can help save storage space and time, but they do not directly protect the data from unauthorized access or disclosure. Differential backups are backups that only copy the data that has changed since the last full backup. Differential backups can also help save storage space and time, but they also do not directly protect the data from unauthorized access or disclosure. Pseudonymization is a process of replacing identifying information in data with artificial identifiers or pseudonyms. Pseudonymization can help enhance the privacy of data by reducing the linkability between data and data subjects, but it does not prevent re-identification or inference attacks.

The value proposition of a PIA is not understood by management is the greatest obstacle to conducting a PIA, as it may result in lack of support, funding, resources or commitment for the PIA process and outcomes. Management may not appreciate or recognize the benefits of a PIA, such as enhancing privacy protection, reducing privacy risks and costs, increasing customer trust and satisfaction, and complying with privacy laws and regulations. Management may also perceive a PIA as a burden, a delay or a hindrance to the system or project development and delivery. The other options are not as significant as the value proposition of a PIA is not understood by management as obstacles to conducting a PIA. Conducting a PIA requires significant funding and resources is an obstacle to conducting a PIA, but it may be overcome by demonstrating the return on investment or the cost-benefit analysis of a PIA. PIAs need to be performed many times in a year is an obstacle to conducting a PIA, but it may be mitigated by adopting a scalable or modular approach to PIAs that can be tailored to different types or levels of systems or projects. The organization lacks knowledge of PIA methodology is an obstacle to conducting a PIA, but it may be resolved by acquiring or developing the necessary skills, tools or guidance for performing PIAs1, p. 67-68 References: 1: CDPSE Review Manual (Digital Version)

The primary purpose of a privacy audit framework is to confirm and demonstrate effectiveness of the privacy program in achieving objectives and regulatory compliance. Historical breaches (B) and benchmarking (D) are by-products; maximizing staff effort (C) is about audit efficiency, not program assurance.

“Privacy audits validate the effectiveness and compliance of the privacy program.”