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| Section | Objectives |
|---|---|
| Topic 1: Privacy Assessment and Audit | - Assessment methodologies
|
| Topic 2: Privacy Governance and Principles | - Fundamental privacy concepts and definitions
|
| Topic 3: Privacy Laws and Regulatory Frameworks | - International privacy regulations
|
| Topic 4: Privacy Risk Management and Assessment | - Risk identification and analysis
|
| Topic 5: Privacy Program Implementation and Operations | - Organizational privacy program design
|
| Topic 6: Incident Management and Data Lifecycle | - Data lifecycle management
|
1. Classify the following scenario as major or minor non-conformity
"An India based organization is expanding operations in Europe To deliver its services, it needs to deal with PI of its customers The organization is not fully aware of how the data protection legislations in EU Member States will affect its operations what will be its liabilities and how it needs to address those. The legal learn was given the responsibility to understand the issues and come out with detailed plan. The legal function did not have any m-house expert in privacy or international law The legal team assigned a senior resource on the job This person used the resources available on the internet to understand the legal privacy issues in EU and based on her research recommended the action plan, which was accepted by the management"
A) Major
B) Both Major & Minor
C) Minor
D) None of the above
2. The method of personal data usage in which the users must explicitly decide not to participate.
A) Opt-In
B) Opt-out
C) Data mining
D) Data matching
3. Which of the following mechanisms or steps is/are likely to be taken by an organization for implementing a privacy program?
i. Deploying physical and technology safeguards to protect personal information assets ii. Privacy consideration in product and service design iii. Privacy implementation to focus only on projects impacted by privacy breaches iv. Benchmarking against industry peers' privacy implementation v. Installing privacy enhancing tools and technologies for the projects dealing with organization's Intellectual Property
A) Only i, ii and iv
B) Only i and ii
C) i, ii, iii and iv
D) All except iii
4. What are the criteria for deciding the role of Data Fiduciary? Tick all that apply.
A) Data Fiduciary is the one who decides the purposes of personal data processing
B) Data Fiduciary is the one who stores the personal data
C) Data Fiduciary is the one who acts on behalf of data processor
D) Data Fiduciary is the one who decides the means of personal data processing
5. FILL BLANK
PIS
The company has a well-defined and effectively implemented security policy. As in case of access control, the security controls vary in different client relationships based on the client requirements but certain basic or hygiene security practices / controls are implemented organization wide. The consultants have advised the information security function to realign the company's security policy, risk assessment, data classification, etc to include privacy aspects. But the consultants are struggling to make information security function understand what exact changes need to be made and the security function itself is unable to figure it out.
(Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion) Introduction and Background XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than
500 clients across industry verticals - BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.
The company is witnessing phenomenal growth in the BPM services over last few years including Finance and Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects. The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).
To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens.
The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.
Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.
Can you please guide the information security function to realign company's security initiatives to include privacy protection, keeping in mind that the client security requirements would vary across relationships?
(250 to 500 words)
Solutions:
| Question # 1 Answer: A | Question # 2 Answer: B | Question # 3 Answer: D | Question # 4 Answer: A,D | Question # 5 Answer: Only visible for members |
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