Achieve Success in the Isaca CDPSE Exam: A Detailed Certified Data Privacy Solutions Engineer Guide

Obtaining user consent is the best way to mitigate the privacy risk associated with setting cookies on a website. This means that the website should inform the users about the purpose, type, and duration of the cookies, and ask for their permission before storing or accessing any cookies on their browsers. This way, the users can exercise their right to control their personal data and opt-in or opt-out of cookies as they wish.

According to the General Data Protection Regulation (GDPR), consent must be freely given, specific, informed, and unambiguous. The website should provide clear and easy-to-understand information about the cookies and their implications for the users’ privacy, and offer a simple and effective way for the users to indicate their consent or refusal. The website should also respect the users’ choice and allow them to withdraw their consent at any time.

Implementing impersonation, ensuring nonrepudiation, and applying data masking are not relevant or effective methods to mitigate the privacy risk associated with setting cookies on a website. Impersonation means accessing or using data on behalf of another user, which could violate their privacy and security. Nonrepudiation means providing proof of the origin, authenticity, and integrity of data, which does not address the issue of user consent or preference. Data masking means hiding or replacing sensitive data with fake or modified data, which does not prevent the storage or access of cookies on the user’s browser.

The first consideration for ensuring that endpoints are protected in line with the privacy policy is hardening the operating systems of endpoint devices. Hardening is a process of applying security configurations and controls to reduce the attack surface and vulnerabilities of an operating system. Hardening can include disabling unnecessary services and features, applying security patches and updates, enforcing strong passwords and encryption, configuring firewall and antivirus settings, and implementing least privilege principles. Hardening the operating systems of endpoint devices can help prevent unauthorized access, data leakage, malware infection, or other threats that may compromise the privacy of personal data stored or processed on those devices.

Detecting malicious access through endpoints, implementing network traffic filtering on endpoint devices, and managing remote access and control are also important aspects of endpoint security, but they are not the first consideration. Rather, they are dependent on or complementary to hardening the operating systems of endpoint devices. For example, detecting malicious access requires having a baseline of normal activity and behavior on the endpoint device, which can be established by hardening. Implementing network traffic filtering requires having a firewall or other network security tool installed and configured on the endpoint device, which is part of hardening. Managing remote access and control requires having authentication and authorization mechanisms in place on the endpoint device, which is also part of hardening.

References: Manage endpoint security policies in Microsoft Intune, ENDPOINT SECURITY POLICY, How To Build An Effective Endpoint Security Policy And Prevent Cyberattacks

The organization should disclose the relationship to those affected in jurisdictions where such disclosures are required, as this is the most appropriate and compliant action to take after identifying a privacy risk related to third-party data collection. Disclosing the relationship to the data subjects is a way of providing transparency and accountability, as well as respecting their rights and choices regarding their personal data. It also helps the organization avoid regulatory fines or sanctions for not complying with the applicable privacy laws or regulations that mandate such disclosures. The other options are not as effective or sufficient as disclosing the relationship, as they do not address the root cause of the risk, do not mitigate the potential harm to the data subjects, or do not align with the privacy principles and best practices.

References: CDPSE Review Manual, 2021, p. 36

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 strategic goals of the organization should be established first before a privacy office starts to develop a data protection and privacy awareness campaign, because they provide the direction, purpose, and scope of the campaign. The strategic goals of the organization reflect its vision, mission, values, and objectives, as well as its alignment with the relevant privacy laws and regulations, stakeholder expectations, and industry best practices. The privacy office should design and implement the awareness campaign in a way that supports and promotes the strategic goals of the organization, as well as measures and evaluates its effectiveness and impact.

References:

• CDPSE Review Manual, 2023 Edition, Domain 1: Privacy Governance, Section 1.1.2: Privacy Strategy Implementation, p. 19
• CDPSE Review Manual, 2023 Edition, Domain 1: Privacy Governance, Section 1.3.2: Privacy Awareness and Training Program, p. 38-39
• ICO launches data awareness campaign1

Data loss prevention (DLP) tools are technologies that help to prevent unauthorized access, use, or transfer of personal data. DLP tools can monitor, detect, and block data leakage or exfiltration from various sources, such as endpoints, networks, cloud services, or email. DLP tools can also enforce data protection policies and compliance requirements, such as encryption, masking, or deletion of sensitive data. DLP tools can help to protect personal data from both internal and external threats, such as malicious insiders, hackers, or accidental exposure.

References:

• Data protection solutions rely on technologies such as data loss prevention (DLP), storage with built-in data protection, firewalls, encryption, and endpoint protection, Cloudian
• Top 10 Hot Data Security And Privacy Technologies, Forbes

The data subject should contact the organization’s chief privacy officer (CPO) first if they believe their personal information has been collected and used without consent. The CPO is the senior executive who is responsible for establishing and maintaining the organization’s privacy vision, strategy, and program. The CPO oversees the development and implementation of privacy policies, procedures, standards, and controls, and ensures that they align with the organization’s business objectives and legal obligations. The CPO also leads the privacy governance structure, such as the privacy steering committee, and coordinates with other stakeholders, such as the data protection authorities, the privacy rights advocates, and the outside privacy counsel, to ensure that privacy is integrated into all aspects of the organization’s operations. The CPO is the primary point of contact for data subjects who have any questions, complaints, or requests regarding their personal information, and who can address their concerns and resolve their issues in a timely and effective manner. References: : CDPSE Review Manual (Digital Version), page 21

Some organizations, typically those that manage large amounts of personal information related to employees, customers, or constituents, will employ a chief privacy officer (CPO). Some organizations have a CPO because applicable regulations such as the Gramm-Leach-Bliley Act (GLBA) require it. Other regulations such as the Health Information Portability and Accountability Act (HIPAA), the Fair Credit Reporting Act (FCRA), and the GLBA place a slate of responsibilities upon an organization that compels them to hire an executive responsible for overseeing compliance.

The chief privacy officer (CPO) is the senior executive who is responsible for establishing and maintaining the organization’s privacy vision, strategy, and program. The CPO oversees the development and implementation of privacy policies, procedures, standards, and controls, and ensures that they align with the organization’s business objectives and legal obligations. The CPO also leads the privacy governance structure, such as the privacy steering committee, and coordinates with other stakeholders, such as the chief data officer (CDO), the information security steering committee, and the legal counsel, to ensure that privacy is integrated into all aspects of the organization’s operations. References: : CDPSE Review Manual (Digital Version), page 21

However, the risks associated with long-term retention have compelled organizations to consider alternatives; one is data archival, the process of preparing data for long-term storage. When organizations are bound by specific laws to retain data for many years, archival provides a viable opportunity to remove data from online transaction systems to other systems or media.

Data archiving is the process of moving data that is no longer actively used to a separate storage device for long-term retention. Data archiving helps to reduce the cost and complexity of data storage, improve the performance and availability of data systems, and comply with data retention policies and regulations. Data archiving should document controls relating to periods of retention for personal data, such as the criteria for determining the retention period, the procedures for deleting or anonymizing data after the retention period expires, and the mechanisms for ensuring the integrity and security of archived data. References: : CDPSE Review Manual (Digital Version), page 123

The best way to ensure an effective data privacy policy is implemented is to align regulatory requirements with business needs, because this will help achieve compliance while also supporting the organization’s objectives, values, and strategies. A data privacy policy should reflect the legal obligations and expectations of the organization, as well as the needs and preferences of its stakeholders, such as customers, employees, partners, and regulators. A data privacy policy should also be flexible and adaptable to changing circumstances and environments12.

References:

• CDPSE Exam Content Outline, Domain 1 – Privacy Governance (Governance, Management & Risk Management), Task 3: Participate in the evaluation of privacy policies, programs and policies for their alignment with legal requirements, regulatory requirements and/or industry best practices3.
• CDPSE Review Manual, Chapter 1 – Privacy Governance, Section 1.2 – Privacy Policy4.