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NEW QUESTION 30
Which of the following parameters should ideally be addressed by a privacy program of an organization?
(Choose all that apply.)
- A. Intellectual Property (IP) protection
- B. Privacy incident response plan and grievance handling
- C. Training and data classification
- D. Environmental security concerns
Answer: B,C
NEW QUESTION 31
Which of the following is outside the scope of an organization's privacy incident management plan?
- A. Communication of privacy incidents
- B. Remediation of incidents
- C. Defers data access rules for business users
- D. Detection of leakage of personal information
Answer: C
NEW QUESTION 32
Which of the following factors is least likely to be considered while implementing or augmenting data security solution for privacy protection?
- A. Training and awareness program for third party organizations
- B. Security controls deployment at the database level
- C. Classification of data type and its usage by various functions in the organization
- D. Information security infrastructure up-gradation in the organization
Answer: A
NEW QUESTION 33
Which among the following would not be characteristic of a good privacy notice?
- A. Comprehensive - explaining all the possible scenarios and processing details making the notice lengthy
- B. Clear and concise
- C. Multi-lingual
- D. Easy to understand
Answer: A
NEW QUESTION 34
Entities should collect personal information from user that is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. This Privacy Principle is called:
- A. Storage Limitation
- B. Use Limitation
- C. Accountability
- D. Collection Limitation
Answer: D
NEW QUESTION 35
FILL BLANK
IUA and PAT
The company has a very mature enterprise level access control policy to restrict access to information. There is a single sign-on platform available to access company resources such as email, intranet, servers, etc. However, the access policy in client relationships varies depending on the client requirements. In fact, in many cases clients provide access ids to the employees of the company and manage them. Some clients also put technical controls to limit access to information such data masking tool, encryption, and anonymizing data, among others. Some clients also record the data collection process to monitor if the employee of the company does not collect more data than is required. Taking cue from the best practices implemented by the clients, the company, through the consultants, thought of realigning its access control policy to include control on data collection and data usage by the business functions and associated third parties. As a first step, the consultants advised the company to start monitoring the PI collection, usage and access by business functions without their knowledge. The IT function was given the responsibility to do the monitoring, as majority of the information was handled electronically. The analysis showed that many times, more information than necessary was collected by the some functions, however, no instances of misuse could be identified. After few days of this exercise, a complaint was registered by a female company employee in the HR function against a male employee in IT support function. The female employee accused the male employee of accessing her photographs stored on a shared drive and posting it on a social networking site.
(Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion) Introduction and Background XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than 500 clients across industry verticals - BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.
The company is witnessing phenomenal growth in the BPM services over last few years including Finance & Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects. The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).
To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens.
The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.
Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.
What should the company do to limit data collection and usage and at the same time ensure that such kinds of incidents don't reoccur? (250 to 500 words)
Answer:
Explanation:
XYZ should strive to create a comprehensive privacy policy that addresses all aspects of data collection, usage and storage. This will both protect the company from legal liabilities as well as create an environment of trust between customers and the organization. It should also ensure that proper security controls are in place for both on-premise systems as well as cloud services. The policy should outline details regarding access privileges and procedures for handling sensitive personal information including photographs.
Further, XYZ should conduct regular training sessions with employees, especially those in IT support functions, to enhance their knowledge about the company's privacy policies and procedures. An employee code of conduct outlining restrictions on the misuse of data must be implemented and communicated clearly to all stakeholders involved in data processing activities. The company should also implement technical measures such as encryption and pseudonymisation of data, which will ensure that the data is only accessible by authorized personnel with proper privileges.
In addition to this, XYZ should also create a framework for breach notification that outlines the steps to be taken in case of any unauthorized access or disclosure of information. The policy should set out procedures for assessing incidents and for informing the relevant authorities as well as affected individuals within a specified timeframe. Finally, XYZ should develop an independent monitoring mechanism to ensure compliance with its privacy policies and procedures. This may include third-party audits, regular evaluation of existing policies, and periodic reviews of employee performance.
By investing in privacy and security controls at both procedural and technical levels, XYZ can ensure that it is able to keep pace with the ever-evolving privacy landscape and provide its customers with the assurance they need.
This will also help the company meet any new regulatory requirements as well as ensure that similar incidents don't reoccur in the future. In this way, XYZ will be able to successfully access and tap into potential markets while reducing legal liabilities associated with data misuse.
The bottom line is that proper investment in privacy and security will yield long-term dividends by enhancing customer trust in the organization. By implementing a comprehensive framework of policies, procedures and technical measures, XYZ can protect personal information from unauthorized access or disclosure, thereby providing increased assurance to customers that their data is safe and secure.
In this way, the company will be better positioned to remain competitive in an increasingly competitive landscape.
NEW QUESTION 36
A newly appointed Data Protection officer is reviewing the organization's existing privacy policy. Which of the following would be the most critical factor for the review process?
- A. Awareness of the business units about the privacy policy
- B. Changes in the legal/regulatory regime
- C. Foreseeable challenges in the effective implementation of the policy
- D. Privacy policies of industry peers
Answer: B
NEW QUESTION 37
The entire assessment process, from commencement to submission of final report to DSCI must be completed within 2 weeks.
- A. False
- B. True
Answer: A
NEW QUESTION 38
FILL BLANK
RCI and PCM
In April 2011, the rules were issued under Section 43A of the IT Act by the Government of India and the
'body corporates' were required to comply with these rules. The Corporate legal team tried to understand and interpret the rules but struggled to understand its applicability esp. to client relationships and business functions. So, the company hired an IT Act legal expert to advise them on the Section 43A rules.
To start with, the company identified the PI dealt with by business functions as part of the earlier visibility exercise, but it wanted to reassure itself. Therefore, a specific exercise was conducted to revisit 'sensitive personal information' dealt by business functions. It was realized that the company collects lot of SPI of its employees and therefore 'reasonable security practices' need to be adhered to by the functions that deal with SPI. It was also ascertained that many of this SPI is being dealt by third parties, some of which are also located outside India. To meet the requirements of the rules, the company reviewed all the contracts and inserted a clause - 'the service provider shall implement reasonable security practices and procedures as per the IT (Amendment) Act, 2008'. Some of the large service providers were ISO 27001 certified and they claimed that they fulfill the requirements of 'reasonable security practices'. However, some SME service providers did not understand what would 'reasonable security practices' imply and requested the company to clarify, which referred them to Rule 8 of the Section 43A. Some small scale service providers expressed their unwillingness to get ISO certified, given the costs involved.
(Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion) Introduction and Background XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than 500 clients across industry verticals - BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.
The company is witnessing phenomenal growth in the BPM services over last few years including Finance & Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects. The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).
To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens.
The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.
Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.
Did the company take sufficient steps to protect SPI dealt by its service providers and ensure that it complies with the regulatory requirements? Was referring to 'reasonable security practices' sufficient in the contracts or the company should have also considered some other measures for privacy protection as well? (250 to 500 words)
Answer:
Explanation:
The consulting arm of XYZ developed a comprehensive privacy program in line with the company's goal to leverage its existing technology infrastructure, resources and capabilities for protecting data. The program had three parts - awareness and training, policy development and implementation. On the awareness front, extensive training was conducted for employees on various aspects of privacy including GDPR compliance.
This was followed by the development and rollout of an enterprise-wide privacy policy which clearly defined the various steps to be taken to protect sensitive personal information (SPI) such as encryption, access controls etc. After this, customer contracts were reviewed for appropriate protection clauses and service providers were made to sign 'reasonable security practices' clauses in their contractual obligations as specified in EU GDPR.
At first glance, it seemed that XYZ had taken adequate steps to protect SPI dealt by its service providers and ensure that it complies with the regulatory requirements. However, on careful scrutiny, there were some lacunae in the program. For instance, as per EU GDPR, personal data must be pseudonymized or encrypted prior to transfer from one entity to another. In this case, though encryption was mentioned in the policy documents but there were no specific measures given for ensuring proper encryption of data before any transfer. Similarly, 'reasonable security practices' clause was included in customer contracts but there was no mention of any tools like firewalls or other means of protecting sensitive information which could have further strengthened the privacy protection efforts made by the company.
Thus, it is clear that XYZ did made some efforts to comply with the EU GDPR but in order to ensure full compliance, more specific measures should have been taken and all contractual obligations must be such that they clearly define the security and privacy controls that need to be put in place between customer/client and service provider. This would further give customers greater assurance of privacy protection from XYZ's services. Going forward, XYZ can consider investing in more advanced technologies like biometrics authentication etc for maximum security of data. Furthermore, the company should also ensure periodic reviews of its policy documents and contracts so as to ensure better protection of sensitive personal information.
Overall, though XYZ took some reasonable steps to protect SPI of its customers, it should have done more by introducing advanced security measures and including stringent contractual obligations for service providers.
This would have enabled the company to achieve full compliance with EU GDPR and ensure greater security of customer's personal data.
NEW QUESTION 39
'Map the legal and compliance requirements to each data element that an organization is dealing with in all of its business processes, enterprise and operational functions, and client relationships.' This an imperative of which DPF practice area?
- A. Visibility over Personal Information (VPI)
- B. Regulatory Compliance Intelligence (RCI)
- C. Privacy Policy and Processes (PPP)
- D. Privacy Organization and Relationship (POR)
Answer: C
NEW QUESTION 40
__________ calls for inclusion of data protection from the onset of the designing of systems.
- A. Privacy by Design
- B. Safeguarding Approach
- C. Agile Model
- D. Logical Design
Answer: A
NEW QUESTION 41
The concept of data adequacy is based on the principle of _________.
- A. Dissimilarity of legislations
- B. Essential assessment
- C. Essential equivalence
- D. Adequate compliance
Answer: C
NEW QUESTION 42
As a privacy assessor, what would most likely be the first artefact you would ask for while assessing an organization which claims that it has implemented a privacy program?
- A. Records of privacy specific training imparted to the employees handling personal information
- B. Personal information management policy
- C. Records of deployed privacy notices and statements
- D. Privacy risk management framework
Answer: D
NEW QUESTION 43
What is a Data Controller?
- A. Entity that shares personal data with third parties
- B. Entity that stores personal data
- C. Entity that collects personal data
- D. Entity that determines the purpose and means for data processing
Answer: D
NEW QUESTION 44
In the landmark case _______________ the Honourable Supreme Court of India reaffirmed the status of Right to Privacy as a Fundamental Right under Part III of the constitution.
- A. Maneka Gandhi vs. Union of India
- B. Justice K. S. Puttaswamy (Retd.) and Anr. vs. Union of India And Ors
- C. M. P. Sharma and others vs. Satish Chandra, District Magistrate, Delhi, and others
- D. Olga Tellis vs. Bombay Municipal Corporation
Answer: B
NEW QUESTION 45
What is a Data Subject? (Choose all that apply.)
- A. An individual who processes the data/information of individuals for providing necessary services
- B. An individual whose data/information is processed
- C. An individual who provides his/her data/information for availing any service
- D. An individual who collects data from illegitimate sources
- E. A company providing PI of its employees for processing
Answer: B,C
NEW QUESTION 46
Which of the following are key contributors that would enhance the complexity in implementing security measures for protection of personal information? (Choose all that apply.)
- A. Data collection through multiple modes and channels
- B. Regulatory requirements to issue privacy notice and data breach notification in specified format
- C. None of the above
- D. Evolution of nimble and flexible business processes affecting access management
Answer: A,B,D
NEW QUESTION 47
Certification once granted, will be valid for period of _______ years subject to surveillance assessments.
- A. 0
- B. 1
- C. 2
- D. 3
Answer: B
NEW QUESTION 48
As a privacy lead assessor assessing the company for DSCI's privacy certification, you are assessing the adequacy of resources and skills in the organization, to address privacy related responsibilities.
Which DSCI Privacy Framework (DPF) practice area is relevant?
- A. Information Usage and Access (IUA)
- B. Visibility over Personal Information (VPI)
- C. Privacy Awareness and Training (PAT)
- D. Privacy Organization and Relationship (POR)
Answer: D
NEW QUESTION 49
Which of the following activities form part of an organization's Visibility over Personal Information (VPI) initiative, according to DSCI Privacy Framework (DPF)?
- A. 'Data processing environment' analysis of the country
- B. 'Data processing environment' analysis of the organization only
- C. 'Data processing environment' analysis of industry peers
- D. 'Data processing environment' analysis of the organization and associated third parties
Answer: D
NEW QUESTION 50
Which of the following are the key factors that need to be considered for determining the applicability of the privacy principles? (Choose all that apply.)
- A. How and where the data is coming in the organization
- B. Organization's commitment to the external stakeholder with respect to privacy
- C. Requirements stipulated by the local authorities from where the organization operating
- D. The role of the organization in determining the purpose of the data collection
Answer: A,D
NEW QUESTION 51
Which of the following are classified as Sensitive Personal Data or Information under Section 43A of ITAA, 2008? (Choose all that apply.)
- A. Caste and religious beliefs
- B. Biometric information
- C. Sexual orientation
- D. Financial information
- E. Medical records and history
- F. Password
Answer: B,C,D,E
NEW QUESTION 52
Privacy enhancing tools aim to allow users to take one or more of the following actions related to their personal data that is sent to, and used by online service providers, merchants or other users:
I) Increase control over their personal data
II) Choose whether to use services anonymously or not
III) Obtain informed consent about sharing their personal data
IV) Opt-out of behavioral advertising or any other use of data
- A. Only I and II
- B. Only I
- C. I, II, III and IV
- D. Only II
Answer: C
NEW QUESTION 53
FILL BLANK
PPP
Based on the visibility exercise, the consultants created a single privacy policy applicable to all the client relationships and business functions. The policy detailed out what PI company deals with, how it is used, what security measures are deployed for protection, to whom it is shared, etc. Given the need to address all the client relationships and business functions, through a single policy, the privacy policy became very lengthy and complex. The privacy policy was published on company's intranet and also circulated to heads of all the relationships and functions. W.r.t. some client relationships, there was also confusion whether the privacy policy should be notified to the end customers of the clients as the company was directly collecting PI as part of the delivery of BPM services. The heads found it difficult to understand the policy (as they could not directly relate to it) and what actions they need to perform. To assuage their concerns, a training workshop was conducted for 1 day. All the relationship and function heads attended the training.
However, the training could not be completed in the given time, as there were numerous questions from the audiences and it took lot of time to clarify.
(Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion) Introduction and Background XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than 500 clients across industry verticals - BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.
The company is witnessing phenomenal growth in the BPM services over last few years including Finance & Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects. The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).
To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens.
The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.
Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.
Do you agree with company's decision to have single privacy policy for all the relationships and functions?
Please justify your view. (250 to 500 words)
Answer:
Explanation:
Explanation
Yes, I agree with the company's decision to have a single privacy policy for all its relationships and functions.
Having a unified privacy policy allows the organization to communicate consistently across multiple channels of communication with customers, partners and vendors. It also ensures that all stakeholders are aware of their rights when dealing with personal data and makes it easier for them to understand their responsibilities when handling such information.
Moreover, having a standardized privacy policy helps to protect the company from potential legal repercussions due to inadequate protection of confidential data. The need for comprehensive protection is especially important in this age where cyber-attacks are becoming increasingly frequent and sophisticated. By putting in place a consistent framework that governs how any organization handles sensitive information can help reduce the risks associated with data breaches.
By demonstrating that the company takes strong measures to protect its customers' personal information, a single privacy policy can help boost the company's reputation and build trust with customers. Compliance with a variety of regulatory requirements is especially important for companies operating in regulated industries, such as banking and healthcare.
In addition, having a unified privacy policy allows organizations to maintain control over how their data is stored and processed. By monitoring who has access to confidential information, companies can identify any potential security vulnerabilities before they are exploited by malicious actors.
To conclude, I support XYZ's decision to have one privacy policy for all its relationships and functions.
Having a unified privacy policy can help the organization protect itself from potential legal risks, boost its reputation and maintain control over how data is stored and used. All in all, it is an important step to ensure that customer data is always kept safe and secure.
NEW QUESTION 54
......
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