Free Isaca CDPSE Practice Exam with Questions & Answers | Set: 3

To ensure the protection of personal data, privacy policies should mandate that access to information system applications be authorized by the business application owner, because they are the ones who are responsible for defining the business requirements, functions, and objectives of the applications. The business application owner can also determine the appropriate level of access for different users or groups based on their roles, responsibilities, and needs. The business application owner can also monitor and review the access control policies and procedures to ensure that they are effective and compliant with the privacy regulations and standards.

References:

• Access Control Policy and Implementation Guides, CSRC
• What is Authorization and Access Control?, ICANN

Prioritizing privacy-related risk scenarios as part of ERM processes is the best way to ensure that the risk responses meet the organizational objectives, because it helps to align the privacy risk management with the overall strategic goals, values, and culture of the organization. ERM is a holistic approach to identify, assess, and manage risks across the organization, taking into account the interdependencies and trade-offs among different types of risks. By integrating privacy-related risk scenarios into the ERM processes, the organization can evaluate the potential impact and likelihood of privacy risks on its mission, vision, and performance, and prioritize the most significant ones for mitigation or acceptance. This can also help to allocate appropriate resources, assign clear roles and responsibilities, and monitor and report on the effectiveness of the risk responses.

References:

• Privacy Risk Management, ISACA Journal
• Enterprise Risk Assessment, Deloitte

One of the foundational goals of data privacy laws is to give people rights over the collection of personal data, such as the right to access, correct, delete, or object to the processing of their data. Privacy laws also aim to protect people’s dignity, autonomy, and self-determination in relation to their personal data. The other options are not accurate or complete descriptions of the purpose of data privacy laws.

References:

• CDPSE Review Manual, Chapter 1 – Privacy Governance, Section 1.1 – Privacy Principles1.
• CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 1 – Privacy Governance, Section 1.2 – Data Privacy Laws and Regulations2.

The best way to validate compliance with agreed-upon service levels established with a third party that processes personal data is to have a contractual right to audit, which means that the organization can conduct audits or inspections of the third party’s privacy practices, policies, and procedures to verify that they meet the contractual obligations and expectations. A contractual right to audit can also help identify and address any privacy risks or gaps that may arise from the third party’s processing of personal data12.

References:

• CDPSE Exam Content Outline, Domain 1 – Privacy Governance (Governance, Management & Risk Management), Task 7: Participate in the management and evaluation of contracts, service levels and practices of vendors and other external parties3.
• CDPSE Review Manual, Chapter 1 – Privacy Governance, Section 1.4 – Third-Party Management4.

Anonymization is a technique that removes or modifies all identifiers in a data set to prevent or limit the identification of the data subjects. Anonymization is the IT privacy practitioner’s best recommendation for an organization that uses analytics derived from archived transaction data to create individual customer profiles for customizing product and service offerings, as it would protect the privacy of the customers by reducing the linkability of the data set with their original identity, and also comply with the data minimization principle that requires limiting the collection, storage and processing of personal data to what is necessary and relevant for the intended purposes. Anonymization would also preserve some characteristics or patterns of the original data that can be used for analysis or customization purposes, without compromising the accuracy or quality of the results. The other options are not as effective as anonymization in this situation. Discontinuing the creation of profiles is not a feasible or desirable option, as it would prevent the organization from achieving its business objectives and providing value to its customers. Implementing strong access controls is a security measure that restricts who can access, view or modify the data, but it does not address the issue of collecting or retaining more personal data than necessary or relevant. Encrypting data at rest is a security measure that transforms plain text data into cipher text using an algorithm and a key, making it unreadable by unauthorized parties, but it does not address the issue of collecting or retaining more personal data than necessary or relevant, and may require additional security measures to protect the encryption keys or certificates1, p. 75-76 References: 1: CDPSE Review Manual (Digital Version)

Requirements definition is a phase of the software development life cycle (SDLC) that involves gathering, analyzing and documenting the functional and non-functional requirements of the software system or application, such as features, performance, security and usability. It is most important to consider privacy by design principles during this phase, as it would help to ensure that privacy is embedded and integrated into the software system or application from the outset, rather than as an afterthought or an add-on. Considering privacy by design principles during requirements definition would also help to avoid costly rework or delays later in the SDLC, as well as to enhance customer trust and satisfaction, and comply with privacy laws and regulations. The other options are not as important as requirements definition in considering privacy by design principles. Application design is a phase of the SDLC that involves creating and specifying the architecture, components, interfaces and data models of the software system or application, based on the requirements defined in the previous phase. Implementation is a phase of the SDLC that involves coding, testing and debugging the software system or application, based on the design specifications created in the previous phase. Testing is a phase of the SDLC that involves verifying and validating that the software system or application meets the requirements and expectations of the users and stakeholders, as well as identifying and fixing any defects or errors1, p. 88-89 References: 1: CDPSE Review Manual (Digital Version)

A virtual private network (VPN) is a technology that creates a secure and encrypted connection over a public network, such as the internet. A VPN should be established first before authorizing remote access to a data store containing personal data, as it protects the data from unauthorized interception, modification, or disclosure by third parties. A VPN also helps to ensure the identity and authenticity of the remote users and devices accessing the data store. References: 2 Domain 2, Task 8

The best way to address privacy concerns when an organization captures personal data from a third party through an open application programming interface (API) is to obtain consent from the data subjects. Consent is a freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they agree to the processing of their personal data by the organization for a defined purpose. Consent is one of the legal bases for processing personal data under various privacy laws and regulations such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA). Obtaining consent from the data subjects can help ensure that they are aware of and agree to the collection and use of their personal data by the organization through the open API. Obtaining consent can also help respect the data subject’s rights and preferences regarding their personal data.

Developing a service level agreement (SLA) with the third party, implementing encryption for the data transmission, or reviewing the specification document of the open API are also good practices for addressing privacy concerns when using an open API to capture personal data from a third party, but they are not the best way. Developing an SLA with the third party can help define the roles, responsibilities, expectations, and obligations of both parties regarding the provision and use of the open API and the personal data involved. Implementing encryption for the data transmission can help protect the confidentiality, integrity, and availability of the personal data transferred between the third party and the organization through the open API. Reviewing the specification document of the open API can help understand the functionality, features, parameters, or requirements of the open API and how it handles personal data.

References: Open APIs and Security Risks | Govenda Board Portal Software, The top API security risks and how to mitigate them - Appinventiv, Critical API security risks: 10 best practices | TechBeacon

A privacy impact assessment (PIA) is a process of analyzing the potential privacy risks and impacts of collecting, using, and disclosing personal data. A PIA should be conducted when there is a change in the data processing activities that may affect the privacy of individuals or the compliance with data protection laws and regulations. One of the scenarios that should trigger the completion of a PIA is when there are new inter-organizational data flows, which means that personal data is shared or transferred between different entities or jurisdictions. This may introduce new privacy risks, such as unauthorized access, misuse, or breach of data, as well as new legal obligations, such as obtaining consent, ensuring adequate safeguards, or notifying authorities.

References:

• PIA Triggers - International Association of Privacy Professionals
• Privacy Impact Assessment - International Association of Privacy Professionals
• GDPR Privacy Impact Assessment
• Data Protection Impact Assessment triggers: Clarity or confusion?

The data owner is the person or entity who has the ultimate authority and responsibility for the protection of personal data collected by an organization. The data owner defines the purpose, scope, classification, and retention of the personal data, as well as the rights and obligations of the data subjects and other parties involved in the data processing. The data owner also ensures that the personal data is handled in compliance with the applicable privacy laws and regulations, as well as the organization’s privacy policies and standards. The data owner may delegate some of the operational tasks to the data processor, data custodian, or data protection officer, but the accountability remains with the data owner.

References: CDPSE Review Manual, 2021, p. 81