[Dec 07, 2025] Genuine CIPM Exam Dumps Free Demo

Printable & Easy to Use Certified Information Privacy Manager CIPM Dumps 100% Same Q&A In Your Real Exam

Target Audience

This exam targets specialists who want to become privacy information managers. These are people who want to be or are already in the data-driven world and would like to be experts in navigating the industry.

 

NEW QUESTION # 70
SCENARIO
Please use the following to answer the next question:
As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically Questionable practices, including unauthorized sales of personal data to marketers.
Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that
"appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.
Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures.
He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.
The CEO likes what he's seen of the company's improved privacy program, but wants additional assurance that it is fully compliant with industry standards and reflects emerging best practices. What would best help accomplish this goal?

• A. An internal audit team accountable to upper management
• B. Revision of the strategic plan to provide a system of technical controls
• C. An external audit conducted by a panel of industry experts
• D. Creation of a self-certification framework based on company policies

Answer: B

NEW QUESTION # 71
Incipia Corporation just trained the last of its 300 employees on their new privacy policies and procedures.
If Incipia wanted to analyze the effectiveness of the training over the next 6 months, which form of trend analysis should they use?

• A. Cyclical.
• B. Irregular.
• C. Statistical.
• D. Standard variance.

Answer: C

NEW QUESTION # 72
SCENARIO
Please use the following to answer the next QUESTION:
Ben works in the IT department of IgNight, Inc., a company that designs lighting solutions for its clients. Although IgNight's customer base consists primarily of offices in the US, some individuals have been so impressed by the unique aesthetic and energy-saving design of the light fixtures that they have requested IgNight's installations in their homes across the globe.
One Sunday morning, while using his work laptop to purchase tickets for an upcoming music festival, Ben happens to notice some unusual user activity on company files. From a cursory review, all the data still appears to be where it is meant to be but he can't shake off the feeling that something is not right. He knows that it is a possibility that this could be a colleague performing unscheduled maintenance, but he recalls an email from his company's security team reminding employees to be on alert for attacks from a known group of malicious actors specifically targeting the industry.
Ben is a diligent employee and wants to make sure that he protects the company but he does not want to bother his hard-working colleagues on the weekend. He is going to discuss the matter with this manager first thing in the morning but wants to be prepared so he can demonstrate his knowledge in this area and plead his case for a promotion.
Going forward, what is the best way for IgNight to prepare its IT team to manage these kind of security events?

• A. Update its data inventory.
• B. IT security awareness training.
• C. Share communications relating to scheduled maintenance.
• D. Tabletop exercises.

Answer: D

Explanation:
The best way for IgNight to prepare its IT team to manage these kind of security events is to conduct tabletop exercises. Tabletop exercises are simulated scenarios that test the organization's ability to respond to security incidents in a realistic and interactive way. Tabletop exercises typically involve:
A facilitator who guides the participants through the scenario and injects additional challenges or variables A scenario that describes a plausible security incident based on real-world threats or past incidents A set of objectives that define the expected outcomes and goals of the exercise A set of questions that prompt the participants to discuss their roles, responsibilities, actions, decisions, and communications during the incident response process A feedback mechanism that collects the participants' opinions and suggestions on how to improve the incident response plan and capabilities Tabletop exercises help an organization prepare for and deal with security incidents by:
Enhancing the awareness and skills of the IT team and other stakeholders involved in incident response Identifying and addressing the gaps, weaknesses, and challenges in the incident response plan and process Improving the coordination and collaboration among the IT team and other stakeholders during incident response Evaluating and validating the effectiveness and efficiency of the incident response plan and process Generating and implementing lessons learned and best practices for incident response The other options are not as effective or useful as tabletop exercises for preparing the IT team to manage security events. Updating the data inventory is a good practice for maintaining an accurate and comprehensive record of the personal data that the organization collects, processes, stores, shares, or disposes of. However, it does not test or improve the organization's incident response capabilities or readiness. IT security awareness training is a good practice for educating the IT team and other employees on the basic principles and practices of cybersecurity. However, it does not simulate or replicate the real-world situations and challenges that the IT team may face during security incidents. Sharing communications relating to scheduled maintenance is a good practice for informing the IT team and other stakeholders of the planned activities and potential impacts on the IT systems and infrastructure. However, it does not prepare the IT team for dealing with unplanned or unexpected security events that may require immediate and coordinated response. Reference: CISA Tabletop Exercise Packages; Cybersecurity Tabletop Exercise Examples, Best Practices, and Considerations; Six Tabletop Exercises to Help Prepare Your Cybersecurity Team

NEW QUESTION # 73
SCENARIO
Please use the following to answer the next QUESTION:
John is the new privacy officer at the prestigious international law firm - A&M LLP. A&M LLP is very proud of its reputation in the practice areas of Trusts & Estates and Merger & Acquisition in both U.S. and Europe.
During lunch with a colleague from the Information Technology department, John heard that the Head of IT, Derrick, is about to outsource the firm's email continuity service to their existing email security vendor - MessageSafe. Being successful as an email hygiene vendor, MessageSafe is expanding its business by leasing cloud infrastructure from Cloud Inc. to host email continuity service for A&M LLP.
John is very concerned about this initiative. He recalled that MessageSafe was in the news six months ago due to a security breach. Immediately, John did a quick research of MessageSafe's previous breach and learned that the breach was caused by an unintentional mistake by an IT administrator. He scheduled a meeting with Derrick to address his concerns.
At the meeting, Derrick emphasized that email is the primary method for the firm's lawyers to communicate with clients, thus it is critical to have the email continuity service to avoid any possible email downtime. Derrick has been using the anti-spam service provided by MessageSafe for five years and is very happy with the quality of service provided by MessageSafe. In addition to the significant discount offered by MessageSafe, Derrick emphasized that he can also speed up the onboarding process since the firm already has a service contract in place with MessageSafe. The existing on-premises email continuity solution is about to reach its end of life very soon and he doesn't have the time or resource to look for another solution. Furthermore, the off-premises email continuity service will only be turned on when the email service at A&M LLP's primary and secondary data centers are both down, and the email messages stored at MessageSafe site for continuity service will be automatically deleted after 30 days.
Which of the following is the most effective control to enforce MessageSafe's implementation of appropriate technical countermeasures to protect the personal data received from A&M LLP?

• A. MessageSafe must apply due diligence before trusting Cloud Inc. with the personal data received from A&M LLP.
• B. MessageSafe must notify A&M LLP of a data breach.
• C. MessageSafe must apply appropriate security controls on the cloud infrastructure.
• D. MessageSafe must flow-down its data protection contract terms with A&M LLP to Cloud Inc.

Answer: B

NEW QUESTION # 74
Which of the following is NOT recommended for effective Identity Access Management?

• A. Credentials (e.g.. password).
• B. Demographics.
• C. User responsibility.
• D. Unique user IDs.

Answer: B

Explanation:
Identity and Access Management (IAM) is a process that helps organizations secure their systems and data by controlling who has access to them and what they can do with that access. Effective IAM includes a number of best practices, such as:
* Unique user IDs: Each user should have a unique ID that is used to identify them across all systems and applications.
* Credentials: Users should be required to provide authentication credentials, such as a password or biometric data, in order to access systems and data.
* User responsibility: Users should be made aware of their responsibilities when it comes to security, such as the need to keep their passwords secret and the importance of reporting suspicious activity.
Demographics refers to the statistical characteristics of a population, such as age, gender, income, etc. While demographic data may be collected and used for various purposes, it is not a recommended practice for effective IAM. Demographic data is not a reliable method of identification or authentication, and it is not used to provide access to systems and data.
References:
https://aws.amazon.com/iam/
https://en.wikipedia.org/wiki/Identity_and_access_management
https://en.wikipedia.org/wiki/Demographics

NEW QUESTION # 75
When building a data privacy program, what is a good starting point to understand the scope of privacy program needs?

• A. Complete a Data Inventory.
• B. Perform Data Protection Impact Assessments (DPIAs).
• C. Perform Risk Assessments
• D. Review Audits.

Answer: A

Explanation:
A data inventory is a good starting point to understand the scope of privacy program needs, as it provides a comprehensive overview of what personal data is collected, processed, stored, shared, and disposed of by the organization. A data inventory can help identify the legal obligations, risks, and gaps in the privacy program, as well as the opportunities for improvement and optimization. The other options are also important components of a privacy program, but they are more effective when based on a data inventory. References: CIPM Body of Knowledge, Domain II: Privacy Program Operational Life Cycle, Task
1: Assess the current state of the privacy program.

NEW QUESTION # 76
Data retention and destruction policies should meet all of the following requirements EXCEPT?

• A. Data destruction triggers and methods should be documented.
• B. The organization should be documenting and reviewing policies of its other functions to ensure alignment (e.g. HR, business development, finance, etc.).
• C. Personal information should be retained only for as long as necessary to perform its stated purpose.
• D. Documentation related to audit controls (third-party or internal) should be saved in a non-permanent format by default.

Answer: D

Explanation:
Documentation related to audit controls (third-party or internal) should be saved in a permanent format by default, not a non-permanent one. This is to ensure that the organization can demonstrate its compliance with the applicable laws and regulations, as well as its own policies and procedures, in case of an audit or a legal challenge. The other options are valid requirements for data retention and destruction policies, as they help to minimize the risks and costs associated with storing personal information beyond its intended purpose. Reference: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 3: Manage data retention and disposal.

NEW QUESTION # 77
SCENARIO
Please use the following to answer the next QUESTION:
Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and assesses the office's strategies for growth.
Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to modernize the office, mostly in regard to the handling of clients' personal data. His first goal is to digitize all the records kept in file cabinets, as many of the documents contain personally identifiable financial and medical data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/ printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing policy by the year's end.
Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following day, to get insight into how the office computer system is currently set-up and managed.
As Richard begins to research more about Data Lifecycle Management (DLM), he discovers that the law office can lower the risk of a data breach by doing what?

• A. Prioritizing the data by order of importance.
• B. Increasing the number of experienced staff to code and categorize the incoming data.
• C. Reducing the volume and the type of data that is stored in its system.
• D. Minimizing the time it takes to retrieve the sensitive data.

Answer: C

Explanation:
Explanation
As Richard begins to research more about Data Lifecycle Management (DLM), he discovers that the law office can lower the risk of a data breach by reducing the volume and the type of data that is stored in its system. This is because storing less data means having less data to protect and less data to lose in case of a breach. By reducing the volume and the type of data that is stored in its system, the law office can also comply with the data minimization principle under the GDPR and other data protection regulations, which requires that personal data should be adequate, relevant and limited to what is necessary for the purposes for which they are processed3 Therefore, this option is a way to lower the risk of a data breach.
The other options are not ways to lower the risk of a data breach by applying DLM principles. Prioritizing the data by order of importance may help to allocate resources and optimize performance, but it does not necessarily reduce the risk of a data breach. Minimizing the time it takes to retrieve the sensitive data may improve efficiency and responsiveness, but it does not necessarily reduce the risk of a data breach. Increasing the number of experienced staff to code and categorize the incoming data may enhance data quality and accuracy, but it does not necessarily reduce the risk of a data breach. References: 3: Article 5 GDPR | General Data Protection Regulation (GDPR); 4: Data Lifecycle Management: A Complete Guide | Splunk

NEW QUESTION # 78
What is one reason the European Union has enacted more comprehensive privacy laws than the United States?

• A. To allow separate industries to set privacy standards.
• B. To ensure there is adequate funding for enforcement.
• C. To allow the free movement of data between member countries.
• D. To ensure adequate enforcement of existing laws.

Answer: C

Explanation:
One reason the European Union has enacted more comprehensive privacy laws than the United States is to allow the free movement of data between member countries. The EU considers data protection as a fundamental right that applies to all individuals within its territory, regardless of their nationality or residence. The EU has adopted a harmonized legal framework for data protection, such as the GDPR1 and the ePrivacy Directive5, that applies to all member states and ensures a consistent level of protection across the EU. The EU also requires that any transfers of personal data outside the EU are subject to adequate safeguards or exceptions that guarantee an equivalent level of protection. The EU's approach to data protection aims to facilitate the internal market and promote economic and social integration among member states by removing barriers and restrictions to the cross-border flow of data. The other options are not reasons why the EU has enacted more comprehensive privacy laws than the US. The EU does not necessarily have more adequate enforcement or funding for its privacy laws than the US, although it does have a network of independent supervisory authorities that monitor and enforce compliance with the EU data protection rules. The EU does not allow separate industries to set privacy standards, but rather imposes uniform and binding rules for all sectors and activities that involve personal data processing. Reference: GDPR; ePrivacy Directive

NEW QUESTION # 79
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 administrative safeguards should be implemented to protect the collected data while in use by Manasa and her product management team?

• A. Implement a policy restricting data access on a "need to know" basis.
• B. Document the data flows for the collected data.
• C. Conduct a Privacy Impact Assessment (PIA) to evaluate the risks involved.
• D. Limit data transfers to the US by keeping data collected in Europe within a local data center.

Answer: A

Explanation:
An administrative safeguard that should be implemented to protect the collected data while in use by Manasa and her product management team is a policy restricting data access on a "need to know" basis. This means that only authorized personnel who have a legitimate business purpose for accessing the data should be able to do so3 This would help to prevent unauthorized or unnecessary access, use, or disclosure of sensitive or personal data by internal or external parties. It would also reduce the risk of data breaches, theft, or loss that could compromise the confidentiality, integrity, and availability of the data4 References: 3: HIPAA Security Series #2 - Administrative Safeguards - HHS.gov; 4: Administrative Safeguards of the Security Rule: What Are They?

NEW QUESTION # 80
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 dat a. 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.
Which of Anton's plans for improving the data management of the company is most unachievable?

• A. His intention to send notice letters to customers and employees.
• B. His intention to transition to electronic storage.
• C. His objective for zero loss of personal information.
• D. His initiative to achieve regulatory compliance.

Answer: C

Explanation:
Anton's objective for zero loss of personal information is the most unachievable among his plans for improving the data management of the company. While this objective is admirable and desirable, it is unrealistic and impractical to guarantee that no personal information will ever be lost due to a data breach or incident. Data breaches are inevitable and unpredictable events that can affect any organization regardless of its size or industry4 Even with the best data security practices and tools in place, there is always a possibility of human error, system failure, malicious attack, or natural disaster that could compromise personal information5 Therefore, Anton should focus on minimizing the likelihood and impact of data breaches rather than aiming for zero loss of personal information. He should also prepare a data breach response plan that outlines how to detect, contain, assess, report, and recover from a data breach in a timely and effective manner6 Reference: 4: [Data Breaches Are Inevitable: Here's How to Protect Your Business]; 5: The Top 5 Causes Of Data Breaches; 6: Data Breach Response: A Guide for Business - Federal Trade Commission

NEW QUESTION # 81
SCENARIO
Please use the following to answer the next QUESTION:
As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically questionable practices, including unauthorized sales of personal data to marketers. Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that "appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.
Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures. He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.
You are charged with making sure that privacy safeguards are in place for new products and initiatives. What is the best way to do this?

• A. Hold a meeting with stakeholders to create an interdepartmental protocol for new initiatives
• B. Develop a plan for introducing privacy protections into the product development stage
• C. Institute Privacy by Design principles and practices across the organization
• D. Conduct a gap analysis after deployment of new products, then mend any gaps that are revealed

Answer: C

Explanation:
Privacy by Design principles ensure that privacy considerations are integrated from the very beginning and throughout the entire product or initiative development process. This proactive approach not only ensures that privacy safeguards are in place from the start but can also be more cost-effective in the long run as it helps prevent potential breaches or issues that might arise later, saving on potential fines, reputational damage, and corrective actions.

NEW QUESTION # 82
If an organization maintains a separate ethics office, to whom would its officer typically report to in order to retain the greatest degree of independence?

• A. The Human Resources Director
• B. The organization's General Counsel
• C. The Board of Directors
• D. The Chief Financial Officer

Answer: C

Explanation:
Explanation/Reference: https://hbr.org/1994/03/managing-for-organizational-integrity

NEW QUESTION # 83
Which is TRUE about the scope and authority of data protection oversight authorities?

• A. The Office of the Privacy Commissioner (OPC) of Canada has the right to impose financial sanctions on violators.
• B. All authority in the European Union rests with the Data Protection Commission (DPC).
• C. The Asia-Pacific Economic Cooperation (APEC) Privacy Frameworks require all member nations to designate a national data protection authority.
• D. No one agency officially oversees the enforcement of privacy regulations in the United States.

Answer: D

Explanation:
The true statement about the scope and authority of data protection oversight authorities is that no one agency officially oversees the enforcement of privacy regulations in the United States. Unlike other regions, such as the European Union or Canada, the United States does not have a comprehensive federal privacy law or a single national data protection authority. Instead, it has a patchwork of sector-specific and state-level laws and regulations, enforced by various federal and state agencies, such as the Federal Trade Commission (FTC), the Department of Health and Human Services (HHS), the Department of Commerce (DOC), etc. Additionally, individuals can also bring private lawsuits against organizations that violate their privacy rights. Reference: [Data Protection Authorities], [Privacy Law in the United States]

NEW QUESTION # 84
Data retention and destruction policies should meet all of the following requirements EXCEPT?

• A. Data destruction triggers and methods should be documented.
• B. The organization should be documenting and reviewing policies of its other functions to ensure alignment (e.g. HR, business development, finance, etc.).
• C. Personal information should be retained only for as long as necessary to perform its stated purpose.
• D. Documentation related to audit controls (third-party or internal) should be saved in a non-permanent format by default.

Answer: D

Explanation:
Explanation
Documentation related to audit controls (third-party or internal) should be saved in a permanent format by default, not a non-permanent one. This is to ensure that the organization can demonstrate its compliance with the applicable laws and regulations, as well as its own policies and procedures, in case of an audit or a legal challenge. The other options are valid requirements for data retention and destruction policies, as they help to minimize the risks and costs associated with storing personal information beyond its intended purpose. References: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task
3: Manage data retention and disposal.

NEW QUESTION # 85
Which of the following best describes proper compliance for an international organization using Binding Corporate Rules (BCRs) as a controller or processor?

• A. All employees are subject to the rules in their entirety, regardless of where the work is taking place.
• B. Employees who control personal data must complete a rigorous certification procedure, as they are exempt from legal enforcement.
• C. Employees must sign an ad hoc contractual agreement each time personal data is exported.
• D. All employees must follow the privacy regulations of the jurisdictions where the current scope of their work is established.

Answer: D

Explanation:
Binding Corporate Rules (BCRs) are a mechanism for international organizations to transfer personal data within their group of companies across different jurisdictions, in compliance with the EU General Data Protection Regulation (GDPR) and other privacy laws. BCRs are legally binding and enforceable by data protection authorities and data subjects. BCRs must ensure that all employees who process personal data follow the privacy regulations of the jurisdictions where the data originates from, regardless of where they are located or where the data is transferred to. Reference: [Binding Corporate Rules], [BCRs for controllers], [BCRs for processors]

NEW QUESTION # 86
When devising effective employee policies to address a particular issue, which of the following should be included in the first draft?

• A. Rationale for the policy.
• B. Explanation of how the policy is applied within the organization.
• C. Points of contact for the employee.
• D. Roles and responsibilities of the different groups of individuals.

Answer: A

Explanation:
When devising effective employee policies to address a particular issue, it is important to include the rationale for the policy in the first draft, as it explains why the policy is needed and what benefits it brings to the organization and its employees. The rationale can also help to gain support and buy-in from the management and staff, as well as to align the policy with the organizational values and goals. The other options are also important elements of an employee policy, but they can be added or refined in later drafts. Reference: CIPM Body of Knowledge, Domain IV: Privacy Program Communication Activities, Task 2: Develop internal communication plans.

NEW QUESTION # 87
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 Eurek a. 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 can Sanjay do to minimize the risks of offering the product in Europe?

• A. Sanjay should document the data life cycle of the data collected by the Handy Helper.
• B. Sanjay should write a privacy policy to include with the Handy Helper user guide.
• C. Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released.
• D. Sanjay should advise the distributor that Omnipresent Omnimedia has certified to the Privacy Shield Framework and there should be no issues.

Answer: A

NEW QUESTION # 88
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CIPM Study Course

The vendor has a training course designed to help candidates pass their CIPM exam. The ‘Learn to Design, Build, and Operate Data Privacy Management Programs’ class focuses on helping the candidate grasp concepts on different business processes in marketing, finance, human resources as well as customer service niches. The specialists are trained on how to make use of privacy programs and reduce the risks posed to their organizations because of poor personal data handling. In particular, this training is ideal for all privacy specialists and also those looking to pass the CIPM exam. The training on the whole will touch on domains such as design, building, and operationalization of data privacy management programs. What’s more, it is available in French, German as well as English. During the training sessions, the candidate will learn how to develop a company’s vision, create teams for data protection, develop and use system frameworks as well as assess their performance. In a nutshell, interested candidates can access such a class through any of the following options:

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