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CIPM Exam Dumps - Certified Information Privacy Manager (CIPM)

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Question # 41

Under the General Data Protection Regulation (GDPR), when would a data subject have the right to require the erasure of his or her data without undue delay?

A.

When the data subject is a public authority.

B.

When the erasure is in the public interest.

C.

When the processing is carried out by automated means.

D.

When the data is no longer necessary for its original purpose.

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Question # 42

What is the key privacy objective in undertaking an evaluation of technical controls?

A.

To review and evaluate gaps in targeted internal privacy awareness training.

B.

To determine if the current privacy framework is adequate for the company's needs.

C.

To evaluate and mitigate third-party risk associated with service provider relationships.

D.

To identify and mitigate privacy risks associated with technical systems and data processing activities.

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Question # 43

SCENARIO

Please use the following to answer the next QUESTION:

Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After having had a successful launch in the United States, the Handy Helper is about to be made available for purchase worldwide.

The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the whole family, including children, but does not provide any further detail or privacy notice. In order to use the application, a family creates a single account, and the primary user has access to all information about the other users. Upon start up, the primary user must check a box consenting to receive marketing emails from Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.

Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European distributor of Handy Helper when he fielded many Questions about the product from the distributor. Sanjay needed to look more closely at the product in order to be able to answer the Questions as he was not involved in the product development process.

In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the

product. This data is all stored in the cloud and is encrypted both during transmission and at rest.

Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is hoping that at some point in the future, the data will reveal insights that could be used to create a fully automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is considered a long-term goal.

What can Sanjay do to minimize the risks of offering the product in Europe?

A.

Sanjay should advise the distributor that Omnipresent Omnimedia has certified to the Privacy Shield Framework and there should be no issues.

B.

Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released.

C.

Sanjay should document the data life cycle of the data collected by the Handy Helper.

D.

Sanjay should write a privacy policy to include with the Handy Helper user guide.

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Question # 44

When building a data privacy program, what is a good starting point to understand the scope of privacy program needs?

A.

Perform Data Protection Impact Assessments (DPIAs).

B.

Perform Risk Assessments

C.

Complete a Data Inventory.

D.

Review Audits.

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Question # 45

SCENARIO

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 grow.

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 hear.

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 unique approach.

If Amira and Sadie's ideas about adherence to the company's privacy policy go unchecked, the Federal Communications Commission (FCC) could potentially take action against NatGen for what?

A.

Deceptive practices.

B.

Failing to institute the hotline.

C.

Failure to notify of processing.

D.

Negligence in consistent training.

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Question # 46

An organization's privacy officer was just notified by the benefits manager that she accidentally sent out the retirement enrollment report of all employees to a wrong vendor.

Which of the following actions should the privacy officer take first?

A.

Perform a risk of harm analysis.

B.

Report the incident to law enforcement.

C.

Contact the recipient to delete the email.

D.

Send firm-wide email notification to employees.

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Question # 47

What have experts identified as an important trend in privacy program development?

A.

The narrowing of regulatory definitions of personal information.

B.

The rollback of ambitious programs due to budgetary restraints.

C.

The movement beyond crisis management to proactive prevention.

D.

The stabilization of programs as the pace of new legal mandates slows.

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Question # 48

What is the main function of the Asia-Pacific Economic Cooperation (APEC) Privacy Framework?

A.

Managing the data flows from parties outside the region.

B.

Establishing legal requirements for privacy protection in the region.

C.

Promoting privacy protection technologies developed in the region.

D.

Promoting consumer trust and business confidence in cross-border data flows.

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