Free IAPP CIPM Exam Questions

Question 1

Which of the following is NOT typically a function of a Privacy Officer?

A : Managing an organization's information security infrastructure.

B : Serving as an interdepartmental liaison for privacy concerns

C : Monitoring an organization's compliance with privacy laws

D : Responding to information access requests from the public

Answer: A

Question 2

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 element of the Privacy by Design (PbD) framework might the Handy Helper violate?

A : Failure to obtain opt-in consent to marketing

B : Failure to observe data localization requirements

C : Failure to implement the least privilege access standard

D : Failure to integrate privacy throughout the system development life cycle

Answer: D

Question 3

SCENARIO

Please use the following to answer the next question:

Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the company,

Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year, news broke that a police

sting operation had revealed a drug ring operating in the Providence, Rhode Island office in the United States.

Video from the office's video surveillance cameras leaked to news operations showed a drug exchange

between Special Handling staff and undercover officers.

In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that upper

management believed had let the criminal elements conduct their illicit transactions. After a few weeks under

Kelly's direction, the office became a model of efficiency and customer service. Kelly monitored his workers'

activities using the same cameras that had recorded the illegal conduct of their former co-workers.

Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The company

has received numerous reports of the staff leaving the office unattended. When Kelly arrived, he found that

even when present, the staff often spent their days socializing or conducting personal business on their mobile

phones. Again, he observed their behaviors using surveillance cameras. He issued written reprimands to six

staff members based on the first day of video alone.

Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data Protection

Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was told that the

company's license for the cameras listed facility security as their main use, but he does not know why this

matters. He has pointed out to his superiors that the company's training programs on privacy protection and

data collection mention nothing about surveillance video.

You are a privacy protection consultant, hired by the company to assess this incident, report on the legal and

compliance issues, and recommend next steps.

What should you advise this company regarding the status of security cameras at their offices in the United

States?

A : security cameras at facilities that are now without them

B : t policies about the purpose and use of the security cameras

C : duce the number of security cameras located inside the building.

D : trict access to surveillance video taken by the security cameras and destroy the recordings after a designated period of time

Answer: B

Question 4

Under the General Data Protection Regulation (GDPR), which situation would be LEAST likely to require a Data Protection Impact Assessment (DPIA)?

A : health clinic processing its patients’ genetic and health data

B : use of a camera system to monitor driving behavior on highways

C : Human Resources department using a tool to monitor its employees’ internet activity

D : online magazine using a mailing list to send a generic daily digest to marketing emails

Answer: D

Question 5

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.

What Data Lifecycle Management (DLM) principle should the company follow if they end up allowing

departments to interpret the privacy policy differently?

A : ove the authenticity of the company's records.

B : Arrange for official credentials for staff members

C : equately document reasons for inconsistencies

D : eate categories to reflect degrees of data importance.

Answer: C