A new business crafting its privacy policy is struggling with how it will define the term "personal data."
Which of the following should inform this decision?
Answer : D
Comprehensive and Detailed Explanation:
The definition of 'personal data' must be based on applicable privacy laws (e.g., GDPR, CCPA, or LGPD), as different regulations define personal data differently.
What is the main reason for conducting a data inventory or data map of your organization?
Answer : C
Comprehensive and Detailed Explanation:
A data inventory or data map helps an organization identify where data is stored, how it flows, and how it is processed---which is crucial for compliance and risk management.
All of the following are accurate regarding the use of technical security controls EXCEPT?
Answer : C
Comprehensive and Detailed Explanation:
While privacy laws require appropriate technical security controls, most laws do not specify exactly which controls must be used. Instead, they mandate organizations to adopt 'appropriate technical and organizational measures'.
Option A (Part of data governance strategy) is correct because security controls support data protection and privacy governance.
Option B (Often satisfy multiple jurisdictions) is correct since common security measures (e.g., encryption, access controls) align with various privacy regulations.
Option D (Security expert involvement) is correct because deploying security controls requires specialized knowledge.
An organization can use Privacy-Enhancing Technologies (PETs) to?
Answer : B
Comprehensive and Detailed Explanation:
Privacy-Enhancing Technologies (PETs) are used to strengthen existing privacy controls by improving data security, minimizing data exposure, and reducing compliance risks.
Option A (Replace current controls) is incorrect because PETs work alongside existing security measures rather than replacing them.
Option C (Ensure compliance) is incorrect because PETs help with compliance but do not guarantee it.
Option D (Produce data for interpretation) misrepresents PETs, as their primary function is protecting data rather than generating insights.
Common PETs include encryption, differential privacy, anonymization, and secure multi-party computation.
SCENARIO
Please use the following to answer the next question:
Liam is the newly appointed information technology (IT) compliance manager at Mesa, a USbased outdoor clothing brand with a global E-commerce presence. During his second week, he is contacted by the company's IT audit manager, who informs him that the auditing team will be conducting a review of Mesa's privacy compliance risk in a month.
A bit nervous about the audit, Liam asks his boss what his predecessor had completed related to privacy compliance before leaving the company. Liam is told that a consent management tool had been added to the website and they commissioned a privacy risk evaluation from a small consulting firm last year that determined that their risk exposure was relatively low given their current control environment. After reading the consultant's report, Liam realized that the scope of the assessment was limited to breach notification laws in the US and the Payment Card Industry's Data Security Standard (PCI DSS).
Not wanting to let down his new team, Liam kept his concerns about the report to himself and figured he could try to put some additional controls into place before the audit. Having some privacy compliance experience in his last role, Liam thought he might start by having discussions with the E-commerce and marketing teams.
The E-commerce Director informed him that they were still using the cookie consent tool forcibly placed on the home screen by the CIO, but could not understand the point since their office was not located in California or Europe. The marketing director touted his department's success with purchasing email lists and taking a shotgun approach to direct marketing. Both directors highlighted their tracking tools on the website to enhance customer experience while learning more about where else the customer had shopped. The more people Liam met with, the more it became apparent that privacy awareness and the general control environment at Mesa needed help.
With three weeks before the audit, Liam updated Mesa's Privacy Notice himself, which was taken and revised from a competitor's website. He also wrote policies and procedures outlining the roles and responsibilities for privacy within Mesa and distributed the document to all departments he knew of with access to personal information.
During this time. Liam also filled the backlog of data subject requests for deletion that had been sent to him by the customer service manager. Liam worked with application owners to remove these individual's information and order history from the customer relationship management (CRM) tool, the enterprise resource planning (ERP). the data warehouse and the email server.
At the audit kick-off meeting. Liam explained to his boss and her team that there may still be some room for improvement, but he thought the risk had been mitigated to an appropriate level based on the work he had done thus far.
After the audit had been completed, the audit manager and Liam met to discuss her team's findings, and much to his dismay. Liam was told that none of the work he had completed prior to the audit followed best practices for governance and risk mitigation. In fact, his actions only opened the company up to additional risk and scrutiny. Based on these findings. Liam worked with external counsel and an established privacy consultant to develop a remediation plan.
Given the feedback provided to Liam after the audit, what maturity level would the audit team most likely have assigned to Mesa's privacy policies and procedures if they use the Privacy Maturity Model (PMM)?
Answer : B
Comprehensive and Detailed Explanation:
Mesa's privacy program lacks structured policies, governance, and consistent application of privacy controls, meaning its privacy practices are at the Ad-hoc maturity level.
Option A (Repeatable) means some processes are in place but are not well-documented or consistently followed. Mesa does not meet this threshold.
Option C (Defined) would require fully documented and standardized privacy policies, which Mesa lacks.
Option D (Managed) means policies are monitored and enforced consistently, which is far beyond Mesa's current state.
The Ad-hoc level is assigned when privacy governance is informal, reactive, and lacks structured policies---exactly the situation Mesa is in.
The first step an organization should take when considering the use of a third-party's AI-based resume ranking tool is to?
Answer : B
Comprehensive and Detailed Explanation:
Before adopting an AI-based resume ranking tool, the organization must assess the tool's privacy impact and legal compliance. This ensures the company understands how the tool processes personal data and whether it introduces risks such as bias, discrimination, or non-compliance with AI and privacy regulations (e.g., GDPR, CCPA, AI Act).
Option A (Stakeholder buy-in) is important, but privacy and regulatory assessments must come first.
Option C (Notifying candidates) is a later step after ensuring compliance and assessing risks.
Option D (Contractual concessions) helps mitigate risk but does not replace due diligence in assessing compliance.
A Privacy Impact Assessment (PIA) and AI Impact Assessment should be conducted before implementation.
A start-up tech company is developing its privacy policies and processes.
Which policy is most important to ensure the organization is successful at processing consumer health information?
Answer : B
Comprehensive and Detailed Explanation:
A consumer health data policy is the most critical document for ensuring that a start-up correctly processes consumer health information while maintaining compliance with relevant laws and privacy best practices.
Option A (Employee notice) focuses on employee privacy but does not directly regulate consumer health data.
Option C (Privacy Impact Assessment - PIA) is a risk assessment tool, not a policy that defines how consumer health data is processed.
Option D (HIPAA privacy notice) is only required for HIPAA-covered entities (such as healthcare providers, insurers, and clearinghouses), but many start-ups may not fall under HIPAA jurisdiction.
A consumer health data policy ensures that the company follows the correct data collection, storage, and processing requirements, regardless of whether HIPAA or another privacy law applies.