Free IAPP CIPM Exam Questions

Question 1

SCENARIO

Please use the following to answer the next question:

Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has

found some degree of disorganization after touring the company headquarters. His uncle Henry had always

focused on production – not data processing – and Anton is concerned. In several storage rooms, he has found

paper files, disks, and old computers that appear to contain the personal data of current and former employees

and customers. Anton knows that a single break-in could irrevocably damage the company's relationship with

its loyal customers. He intends to set a goal of guaranteed zero loss of personal information.

To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the

company. However, Kenneth – his uncle's vice president and longtime confidante – wants to hold off on Anton's

idea in favor of converting any paper records held at the company to electronic storage. Kenneth believes this

process would only take one or two years. Anton likes this idea; he envisions a password-protected system that

only he and Kenneth can access.

Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it

will simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware

store down the street will be responsible for their own information management. Then, any unneeded subsidiary

data still in Anton's possession can be destroyed within the next few years.

After learning of a recent security incident, Anton realizes that another crucial step will be notifying customers.

Kenneth insists that two lost hard drives in question are not cause for concern; all of the data was encrypted

and not sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice

letters to all employees and customers to be safe.

Anton must also check for compliance with all legislative, regulatory, and market requirements related to

privacy protection. Kenneth oversaw the development of the company's online presence about ten years ago,

but Anton is not confident about his understanding of recent online marketing laws. Anton is assigning another

trusted employee with a law background the task of the compliance assessment. After a thorough analysis,

Anton knows the company should be safe for another five years, at which time he can order another check.

Documentation of this analysis will show auditors due diligence.

Anton has started down a long road toward improved management of the company, but he knows the effort is

worth it. Anton wants his uncle's legacy to continue for many years to come.

In terms of compliance with regulatory and legislative changes, Anton has a misconception regarding?

A : The timeline for monitoring.

B : The method of recordkeeping

C : The use of internal employees

D : The type of required qualifications.

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 step in the system development process did Manasa skip?

A : Obtain express written consent from users of the Handy Helper regarding marketing

B : Work with Sanjay to review any necessary privacy requirements to be built into the product.

C : Certify that the Handy Helper meets the requirements of the EU-US Privacy Shield Framework

D : Build the artificial intelligence feature so that users would not have to input sensitive information into the Handy Helper

Answer: B

Question 3

A Data Privacy Officer (DPO) who posts privacy message reminders on posters and on company video screens throughout the office to reinforce the organization's privacy message is furthering which organizational program?

A : blic Service.

B : areness

C : aining

D : hics

Answer: B

Question 4

SCENARIO

Please use the following to answer the next question:

Jonathan recently joined a healthcare payment processing solutions company as a senior privacy manager.

One morning, Jonathan awakens to several emails informing him that an individual cloud server failed due to a

flood in its server room, damaging its hardware and destroying all the data the company had stored on that

drive. Jonathan was not aware that the company had this particular cloud account or that any data was being

stored there because it was not included in the data mapping or data inventory provided to him by his

predecessor. Jonathan's predecessor conducted a data inventory and mapping exercise 4 years ago and

updated it on an annual basis.

Renee works in the sales department and tells Jonathan that she doesn't think that account had been used

since the company moved to a bigger cloud vendor three years ago. She also advised him that the account was

mostly used by Human Resources (HR) and Accounts Payable (AP). Jonathan speaks to both departments and

learns that each had met with his predecessor multiple times and explained they saved sensitive personal data

on that drive, including health and financial related personal data and "other stuff." Jonathan also learns that the

data stored in that account was not backed up pursuant to company policy. Jonathan asks his IT department

who had access to that particular account and learns that there were no access controls in place, making the

account available to anyone in the company, despite the purported sensitivity of the data being stored there.

Jonathan is panicking as the data can't be recovered, and he can't determine exactly what data was saved on

that account or to whom it belongs. Two days later, the company receives 32 data subject access requests and

Accounts Payable confirms Jonathan's worry that these data subjects' personal data was likely stored on this

account. He searches for the company's data subject access request policy, but later learns it doesn't exist.

Based on the scenario above, what is the most appropriate next step Jonathan should take?

A : nsult with the legal team to determine how to address the data subjects' requests and determine the risk of noncompliance.

B : nsult with other key stakeholders to create a presentation on the incident and lessons learned for the board of directors.

C : nsult with the public relations team to discuss potential brand impact of not responding to the data subjects' requests.

D : nsult with the IT team to understand how and why this cloud account was not disabled.

Answer: A

Question 5

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