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Q89. Which of the following is the BEST indication of a highly effective privacy training program?

Members of the workforce understand their roles in protecting data privacy

Recent audits have no findings or recommendations related to data privacy

No privacy incidents have been reported in the last year

HR has made privacy training an annual mandate for the organization_

Explanation
The best indication of a highly effective privacy training program is that members of the workforce understand their roles in protecting data privacy, because this shows that the training program has successfully raised the awareness and knowledge of the workforce on the importance, principles and practices of data privacy, and how they can contribute to the organization’s privacy objectives and compliance. According to ISACA, one of the key elements of a privacy training program is to define and communicate the roles and responsibilities of the workforce in relation to data privacy1. Members of the workforce who understand their roles in protecting data privacy are more likely to follow the privacy policies and procedures, report any privacy incidents or issues, and support the privacy culture of the organization2. Recent audits have no findings or recommendations related to data privacy, no privacy incidents have been reported in the last year, and HR has made privacy training an annual mandate for the organization are not as reliable as members of the workforce understand their roles in protecting data privacy, as they do not necessarily reflect the effectiveness of the privacy training program, but rather the performance of other factors such as audit processes, incident management systems, or HR policies.

Q90. An organization’s data destruction guidelines should require hard drives containing personal data to go through which of the following processes prior to being crushed?

Low-level formatting

Remote partitioning

Degaussing

Hammer strike

Q91. Which of the following should be established FIRST before authorizing remote access to a data store containing personal data?

Network security standard

Multi-factor authentication

Virtual private network (VPN)

Q92. Which of the following is the MOST effective remote access model for reducing the likelihood of attacks originating from connecting devices?

Thick client desktop with virtual private network (VPN) connection

Remote wide area network (WAN) links

Thin Client remote desktop protocol (RDP)

Site-to-site virtual private network (VPN)

Explanation
A thin client remote desktop protocol (RDP) is the most effective remote access model for reducing the likelihood of attacks originating from connecting devices, because it minimizes the amount of data and processing that occurs on the remote device. A thin client RDP only sends keyboard, mouse and display information between the remote device and the server, while the actual processing and storage of data happens on the server. This reduces the exposure of sensitive data and applications to potential attackers who may compromise the remote device.
References:
* CDPSE Review Manual, Chapter 2 – Privacy Architecture, Section 2.3 – Privacy Architecture Implementation1.
* CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 2 – Privacy Architecture, Section 2.4 – Remote Access2.

Q93. Which of the following is the BEST way to protect personal data in the custody of a third party?

Have corporate counsel monitor privacy compliance.

Require the third party to provide periodic documentation of its privacy management program.

Include requirements to comply with the organization’s privacy policies in the contract.

Add privacy-related controls to the vendor audit plan.

In GDPR parlance, organizations that use third-party service providers are often, but not always, considered data controllers, which are entities that determine the purposes and means of the processing of personal data, which can include directing third parties to process personal data on their behalf. The third parties that process data for data controllers are known as data processors.

Q94. Of the following, who should be PRIMARILY accountable for creating an organization’s privacy management strategy?

Chief data officer (CDO)

Privacy steering committee

Information security steering committee

Chief privacy officer (CPO)

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.

Q95. Which of the following is the BEST way to protect the privacy of data stored on a laptop in case of loss or theft?

Strong authentication controls

Remote wipe

Regular backups

Endpoint encryption

Explanation
Endpoint encryption is a security practice that transforms the data stored on a laptop or other device into an unreadable format using a secret key or algorithm. Endpoint encryption protects the privacy of data in case of loss or theft, by ensuring that only authorized parties can access and use the data, while unauthorized parties cannot decipher or modify the data without the key or algorithm. Endpoint encryption also helps to comply with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which require data controllers and processors to implement appropriate technical and organizational measures to safeguard personal data.
The other options are less effective or irrelevant for protecting the privacy of data stored on a laptop in case of loss or theft. Strong authentication controls, such as passwords, biometrics or multifactor authentication, are important for verifying the identity and access rights of users, but they do not protect the data from being accessed by bypassing or breaking the authentication mechanisms. Remote wipe is a feature that allows users or administrators to erase the data on a lost or stolen device remotely, but it depends on the availability of network connection and device power, and it may not prevent data recovery by sophisticated tools. Regular backups are a process of creating copies of data for recovery purposes, such as in case of data loss or corruption, but they do not protect the data from being accessed by unauthorized parties who may obtain the backup media or files.
References:
* An Ethical Approach to Data Privacy Protection – ISACA, section 2: “Encryption is one of the most effective security controls available to enterprises, but it can be challenging to deploy and maintain across a complex enterprise landscape.”
* How to Protect and Secure Your Data in 10 Ways – TechRepublic, section 1: “Encrypt your hard drive Most work laptops use BitLocker to encrypt local files. That way, if the computer is stolen or hacked, the data it contains will be useless to the malicious actor.”
* 10 Tips to Protect Your Files on PC and Cloud – microsoft.com, section 1: “Encrypt your hard drive Most work laptops use BitLocker to encrypt local files. That way, if the computer is stolen or hacked, the data it contains will be useless to the malicious actor.”
* 11 practical ways to keep your IT systems safe and secure | ICO, section 1: “Use strong passwords and multi-factor authentication Make sure you use strong passwords on smartphones, laptops, tablets, email accounts and any other devices or accounts where personal information is stored.”

Q96. Which of the following is the BEST way to validate that privacy practices align to the published enterprise privacy management program?

Conduct an audit.

Report performance metrics.

Perform a control self-assessment (CSA).

Conduct a benchmarking analysis.

Explanation
The best way to validate that privacy practices align to the published enterprise privacy management program is to conduct an audit. An audit is an independent and objective examination of evidence to provide assurance that privacy practices are effective and compliant with the enterprise privacy management program. An audit can also identify any gaps or weaknesses in the privacy practices and provide recommendations for improvement. An audit can be conducted internally or externally, depending on the scope, objectives, and standards of the audit. References: : CDPSE Review Manual (Digital Version), page 83

Q97. Which of the following BEST supports an organization’s efforts to create and maintain desired privacy protection practices among employees?

Skills training programs

Awareness campaigns

Performance evaluations

Code of conduct principles

Q98. Which of the following is the MOST important consideration when choosing a method for data destruction?

Granularity of data to be destroyed

Validation and certification of data destruction

Time required for the chosen method of data destruction

Level and strength of current data encryption

Explanation
Validation and certification of data destruction is the most important consideration when choosing a method for data destruction, because it provides evidence that the data has been destroyed beyond recovery and that the organization has complied with the applicable information security frameworks and legal requirements.
Validation and certification can also help to prevent data breaches, avoid legal liabilities, and enhance the organization’s reputation and trustworthiness. Different methods of data destruction may have different levels of validation and certification, depending on the type of media, the sensitivity of the data, and the standards and guidelines followed. For example, some methods may require a third-party verification or audit, while others may generate a certificate of destruction or a report of erasure. Therefore, the organization should choose a method that can provide sufficient validation and certification for its specific needs and obligations.
References:
* Secure Data Disposal and Destruction: 6 Methods to Follow, KirkpatrickPrice
* Data Destruction Standards and Guidelines, BitRaser
* Best Practices for Data Destruction, U.S. Department of Education

Q99. Which of the following is MOST important when developing an organizational data privacy program?

Obtaining approval from process owners

Profiling current data use

Following an established privacy framework

Performing an inventory of all data

Q100. Which of the following should be of GREATEST concern when an organization wants to store personal data in the cloud?

The organization’s potential legal liabilities related to the data

The data recovery capabilities of the storage provider

The data security policies and practices of the storage provider

Any vulnerabilities identified in the cloud system

Q101. Which of the following is the GREATEST obstacle to conducting a privacy impact assessment (PIA)?

Conducting a PIA requires significant funding and resources.

PIAs need to be performed many times in a year.

The organization lacks knowledge of PIA methodology.

The value proposition of a PIA is not understood by management.

Explanation
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)

Q102. Which of the following BEST ensures data confidentiality across databases?

Logical data model

Data normalization

Data catalog vocabulary

Data anonymization

Explanation
The best way to ensure data confidentiality across databases is to use data anonymization, which is a process of removing or modifying personal or sensitive data from a dataset so that it cannot be linked or attributed to a specific individual or entity. Data anonymization helps protect the privacy and security of the data subjects, as well as comply with the applicable data protection laws and regulations. Data anonymization can be achieved by using various techniques, such as masking, encryption, aggregation, generalization, perturbation, or synthetic data generation12.
References:
* CDPSE Review Manual, Chapter 3 – Data Lifecycle, Section 3.3 – Data Anonymization3.
* CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 3 – Data Lifecycle, Section 3.4 – Data Anonymization4.

Q103. Which of the following is the BEST way to manage different IT staff access permissions for personal data within an organization?

Mandatory access control

Network segmentation

Dedicated access system

Role-based access control

Q104. Which of the following is the PRIMARY reason for an organization to use hash functions when hardening application systems involved in biometric data processing?

To reduce the risk of sensitive data breaches

To meet the organization’s security baseline

To ensure technical security measures are effective

To prevent possible identity theft

Explanation
The primary reason for an organization to use hash functions when hardening application systems involved in biometric data processing is to reduce the risk of sensitive data breaches, because hash functions are one-way mathematical functions that transform biometric data into a unique and irreversible representation that cannot be reconstructed or reversed. This means that even if an attacker gains access to the hashed biometric data, they cannot use it to identify or impersonate the individual. Hash functions also help preserve the privacy and confidentiality of biometric data by preventing unauthorized access, modification, or disclosure.
References:
* CDPSE Exam Content Outline, Domain 2 – Privacy Architecture (Privacy Architecture Implementation), Task 2: Implement privacy solutions1.
* CDPSE Review Manual, Chapter 2 – Privacy Architecture, Section 2.3 – Privacy Architecture Implementation2.
* CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 2 – Privacy Architecture, Section 2.4 – Remote Access3.

Q105. When using pseudonymization to prevent unauthorized access to personal data, which of the following is the MOST important consideration to ensure the data is adequately protected?

The data must be protected by multi-factor authentication.

The identifier must be kept separate and distinct from the data it protects.

The key must be a combination of alpha and numeric characters.

The data must be stored in locations protected by data loss prevention (DLP) technology.

Q106. An organization is developing a wellness smartwatch application and is considering what information should be collected from the application users. Which of the following is the MOST legitimate information to collect for business reasons in this situation?

Height, weight, and activities

Sleep schedule and calorie intake

Education and profession

Race, age, and gender

Explanation
Height, weight, and activities are the most legitimate information to collect for business reasons in this situation, as they are directly related to the purpose and functionality of a wellness smartwatch application that aims to monitor and improve the health and fitness of its users. Collecting height, weight, and activities would 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. The other options are not legitimate information to collect for business reasons in this situation, as they are not related to the purpose and functionality of a wellness smartwatch application and may violate the privacy rights and preferences of its users. Collecting sleep schedule and calorie intake may be useful for some users who want to track their sleep quality and nutrition intake, but they are not essential for a wellness smartwatch application and may require additional consent or justification from the users. Collecting education and profession may be irrelevant for a wellness smartwatch application and may be used for other purposes, such as marketing or profiling, without the consent or knowledge of the users. Collecting race, age, and gender may be sensitive for some users who do not want to disclose their personal characteristics or identity, and may require additional safeguards or measures to protect their privacy1, p. 75-76 References: 1: CDPSE Review Manual (Digital Version)

Q107. What should be the PRIMARY consideration of a multinational organization deploying a user and entity behavior analytics (UEBA) tool to centralize the monitoring of anomalous employee behavior?

Cross-border data transfer

Support staff availability and skill set

User notification

Global public interest

Explanation
The primary consideration of a multinational organization deploying a user and entity behavior analytics (UEBA) tool to centralize the monitoring of anomalous employee behavior is cross-border data transfer, because it may involve the transfer of personal data across different jurisdictions with different privacy laws and regulations. The organization needs to ensure that it complies with the applicable legal requirements and safeguards the privacy rights of its employees when transferring their data to a central location for analysis.
The other options are secondary or operational considerations that may not have a significant impact on the privacy of the employees.
References:
* CDPSE Exam Content Outline, Domain 2 – Privacy Architecture (Privacy Architecture Implementation), Task 3: Implement privacy solutions1.
* CDPSE Review Manual, Chapter 2 – Privacy Architecture, Section 2.4 – Cross-Border Data Transfer2.
* CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 2 – Privacy Architecture, Section 2.5 – Cross-Border Data Transfer3.

Q108. Which of the following is the BEST way to protect the privacy of data stored on a laptop in case of loss or theft?

Strong authentication controls

Remote wipe

Regular backups

Endpoint encryption

Q109. What is the BES T way for an organization to maintain the effectiveness of its privacy breach incident response plan?
* Require security management to validate data privacy security practices.
* Conduct annual data privacy tabletop exercises

Hire a third party to perform a review of data privacy processes.

Involve the privacy office in an organizational review of the incident response plan.

Explanation
The best way for an organization to maintain the effectiveness of its privacy breach incident response plan is to conduct annual data privacy tabletop exercises. A tabletop exercise is a simulated scenario that tests the organization’s ability to respond to a privacy breach incident in a realistic and interactive way. A tabletop exercise can help the organization to evaluate the roles and responsibilities of the incident response team, identify the gaps and weaknesses in the plan, improve the communication and coordination among the stakeholders, and update the plan based on the lessons learned and best practices12. A tabletop exercise can also enhance the awareness and readiness of the organization to handle privacy breach incidents in a timely and effective manner3. References:
* ISACA CDPSE Review Manual, Chapter 4, Section 4.3.2
* ISACA Journal, Volume 4, 2019, “Tabletop Exercises: Three Sample Scenarios”
* ISACA Journal, Volume 6, 2017, “Privacy Breach Response: Preparing for the Inevitable”

Q110. Which of the following should be done FIRST before an organization migrates data from an on-premise solution to a cloud-hosted solution that spans more than one jurisdiction?

Ensure data loss prevention (DLP) alerts are turned on.

Encrypt the data while it is being migrated.

Conduct a penetration test of the hosted solution.

Assess the organization’s exposure related to the migration.

Explanation
The best answer is D. Assess the organization’s exposure related to the migration.
A comprehensive explanation is:
Before an organization migrates data from an on-premise solution to a cloud-hosted solution that spans more than one jurisdiction, it should first assess its exposure related to the migration. This means that the organization should identify and evaluate the potential risks and benefits of moving its data to the cloud, taking into account the legal, regulatory, contractual, and ethical obligations and implications of doing so.
Some of the factors that the organization should consider in its assessment are:
* The nature, sensitivity, and value of the data being migrated, and the impact of its loss, theft, corruption, or disclosure on the organization and its stakeholders.
* The security, privacy, and compliance requirements and standards that apply to the data in each jurisdiction where it is stored, processed, or accessed, and the differences or conflicts among them.
* The trustworthiness, reliability, and reputation of the cloud service provider and its subcontractors, and the terms and conditions of their service level agreements (SLAs) and contracts.
* The availability, performance, scalability, and cost-effectiveness of the cloud-hosted solution compared to the on-premise solution, and the trade-offs involved.
* The technical feasibility and complexity of migrating the data from the on-premise solution to the cloud-hosted solution, and the tools and methods needed to do so.
* The organizational readiness and capability to manage the change and transition from the on-premise solution to the cloud-hosted solution, and the training and support needed for the staff and users.
By conducting a thorough assessment of its exposure related to the migration, the organization can make an informed decision about whether to proceed with the migration or not, or under what conditions or modifications. The assessment can also help the organization to plan and implement appropriate measures and controls to mitigate or avoid any negative consequences and enhance or maximize any positive outcomes of the migration.
Ensuring data loss prevention (DLP) alerts are turned on (A), encrypting the data while it is being migrated (B), and conducting a penetration test of the hosted solution are all good practices to protect data privacy and security when migrating data from an on-premise solution to a cloud-hosted solution that spans more than one jurisdiction. However they are not the first steps that should be done before the migration. They are more relevant during or after the migration process. They also do not address other aspects of exposure related to the migration, such as legal, regulatory, contractual, or ethical issues.
References:
* Data Migration: On-Premise to Cloud – 10 Steps to Success1
* 8 Best Practices for On-Premises to Cloud Migration2
* 5 Steps for a Successful On-Premise to Cloud Migration3
* Extend on-premises data solutions to the cloud4
* On Premise to Cloud migration tool5

Q111. Which of the following should be used to address data kept beyond its intended lifespan?

Data minimization

Data anonymization

Data security

Data normalization

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