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?
A
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.
Reference:
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
.
Which of the following should be the FIRST consideration when conducting a privacy impact
assessment (PIA)?
A
Explanation:
The first consideration when conducting a privacy impact assessment (PIA) is the applicable privacy
legislation that governs the collection, processing, storage, transfer, and disposal of personal data
within the scope of the assessment. The applicable privacy legislation may vary depending on the
jurisdiction, sector, or purpose of the data processing activity. The PIA should identify and comply
with the relevant legal requirements and obligations for data protection and privacy, such as
obtaining consent, providing notice, ensuring data quality and security, respecting data subject
rights, and reporting data breaches. The applicable privacy legislation also determines the criteria,
methodology, and documentation for conducting the PIA.
Reference:
ISACA, Performing an Information Security and Privacy Risk Assessment1
ISACA, Best Practices for Privacy Audits2
ISACA, GDPR Data Protection Impact Assessments3
ISACA, GDPR Data Protection Impact Assessment Template4
Which of the following BEST represents privacy threat modeling methodology?
B
Explanation:
Privacy threat modeling is a methodology for identifying and mitigating privacy threats in a software
architecture. It helps to ensure that privacy is considered in the design and development of software
systems, and that privacy risks are minimized or eliminated. Privacy threat modeling typically
involves the following steps: defining the scope and context of the system, identifying the data flows
and data elements, identifying the privacy threats and their sources, assessing the impact and
likelihood of the threats, and applying appropriate countermeasures to mitigate the
threats. Reference: : CDPSE Review Manual (Digital Version), page 97
An organization is creating a personal data processing register to document actions taken with
personal dat
a. Which of the following categories should document controls relating to periods of retention for
personal data?
A
Explanation:
However, the risks associated with long-term retention have compelled organizations to consider
alternatives; one is data archival, the process of preparing data for long-term storage. When
organizations are bound by specific laws to retain data for many years, archival provides a viable
opportunity to remove data from online transaction systems to other systems or media.
Data archiving is the process of moving data that is no longer actively used to a separate storage
device for long-term retention. Data archiving helps to reduce the cost and complexity of data
storage, improve the performance and availability of data systems, and comply with data retention
policies and regulations. Data archiving should document controls relating to periods of retention for
personal data, such as the criteria for determining the retention period, the procedures for deleting
or anonymizing data after the retention period expires, and the mechanisms for ensuring the
integrity and security of archived data. Reference: : CDPSE Review Manual (Digital Version), page 123
Data collected by a third-party vendor and provided back to the organization may not be protected
according to the organization’s privacy notice. Which of the following is the BEST way to address this
concern?
D
Explanation:
The best way to address the concern that data collected by a third-party vendor and provided back to
the organization may not be protected according to the organization’s privacy notice is to validate
contract compliance. This means that the organization should verify that the third-party vendor is
adhering to the terms and conditions of the contract, which should include clauses on data
protection, privacy, and security. The contract should also specify the obligations and responsibilities
of both parties regarding data collection, processing, storage, transfer, retention, and disposal. By
validating contract compliance, the organization can ensure that the third-party vendor is following
the same privacy standards and practices as the organization.
Reference:
ISACA, CDPSE Review Manual 2021, Chapter 2: Privacy Governance, Section 2.3: Third-Party
Management, p. 51-52.
ISACA, Data Privacy Audit/Assurance Program, Control Objective 8: Third-Party Management, p.
14-
During the design of a role-based user access model for a new application, which of the following
principles is MOST important to ensure data privacy is protected?
D
Explanation:
The need-to-know basis principle is a security principle that states that access to personal data
should be limited to those who have a legitimate purpose for accessing it. The need-to-know basis
principle helps to protect data privacy by minimizing the exposure of personal data to unauthorized
or unnecessary parties, reducing the risk of data breaches, leaks, or misuse. The need-to-know basis
principle should be applied when designing a role-based user access model for a new application, by
defining clear roles and responsibilities for different users, granting access rights based on their roles
and functions, and enforcing access controls and audits to monitor and verify data
access. Reference: : CDPSE Review Manual (Digital Version), page 105
Which of the following should FIRST be established before a privacy office starts to develop a data
protection and privacy awareness campaign?
B
Explanation:
The strategic goals of the organization should be established first before a privacy office starts to
develop a data protection and privacy awareness campaign, because they provide the direction,
purpose, and scope of the campaign. The strategic goals of the organization reflect its vision, mission,
values, and objectives, as well as its alignment with the relevant privacy laws and regulations,
stakeholder expectations, and industry best practices. The privacy office should design and
implement the awareness campaign in a way that supports and promotes the strategic goals of the
organization, as well as measures and evaluates its effectiveness and impact.
Reference:
CDPSE Review Manual, 2023 Edition, Domain 1: Privacy Governance, Section 1.1.2: Privacy Strategy
Implementation, p. 19
CDPSE Review Manual, 2023 Edition, Domain 1: Privacy Governance, Section 1.3.2: Privacy
Awareness and Training Program, p. 38-39
ICO launches data awareness campaign1
Reference: https://www.isaca.org/resources/isaca-journal/issues/2020/volume-5/building-a-
privacy-culture
Which of the following features should be incorporated into an organization’s technology stack to
meet privacy requirements related to the rights of data subjects to control their personal data?
B
Explanation:
Any organization collecting information about EU residents is required to operate with transparency
in collecting and using their personal information. Chapter III of the GDPR defines eight data subject
rights that have become foundational for other privacy regulations around the world:
Right to access personal data. Data subjects can access the data collected on them.
One of the privacy requirements related to the rights of data subjects is the right to access, which
means that individuals have the right to obtain a copy of their personal data, as well as information
about how their data is processed, by whom, for what purposes, and for how long. To meet this
requirement, an organization’s technology stack should incorporate features that allow individuals to
have direct access to their data, such as self-service portals, dashboards, or applications. This way,
individuals can exercise their right to access without relying on intermediaries or manual processes,
which can be inefficient, error-prone, or insecure. Reference: : CDPSE Review Manual (Digital
Version), page 137
Which of the following is the GREATEST concern for an organization subject to cross-border data
transfer regulations when using a cloud service provider to store and process data?
D
Explanation:
Reference: https://www.isaca.org/resources/isaca-journal/past-issues/2014/data-owners-
responsibilities-when-migrating-to-the-cloud
Cross-border data transfer regulations are laws and rules that govern the movement of personal data
across national or regional boundaries. They aim to protect the privacy rights and interests of the
data subjects, and to ensure that their personal data are not subject to lower or incompatible
standards of protection in other jurisdictions. Examples of cross-border data transfer regulations
include the General Data Protection Regulation (GDPR) in the European Union, the California
Consumer Privacy Act (CCPA) in the United States, and the Personal Information Protection Law
(PIPL) in China.
When an organization uses a cloud service provider to store and process data, it may face the risk of
transferring personal data to a region with different data protection requirements, such as a region
that has not been recognized as providing adequate or equivalent levels of protection by the original
jurisdiction, or a region that has conflicting or incompatible laws or regulations with the original
jurisdiction. This may result in the following consequences for the organization:
It may violate the cross-border data transfer regulations of the original jurisdiction, and face legal
sanctions, fines, or lawsuits from the regulators, customers, or data subjects.
It may lose control or visibility over the personal data, and expose them to unauthorized or unlawful
access, use, modification, or disclosure by the cloud service provider or third parties.
It may compromise the trust and confidence of the customers and data subjects, and damage its
reputation and competitiveness.
Therefore, an organization subject to cross-border data transfer regulations should carefully assess
and manage the risks of using a cloud service provider to store and process data, and ensure that it
has appropriate safeguards and mechanisms in place to protect the privacy of personal data across
borders.
Reference:
Cross-Border Data Transfer and Data Localization Requirements … - ISACA
, section 1: “As a result,
China’s National People’s Congress (NPC) and the National Committee of the Chinese People’s
Political Consultative Conference (PCC) put forward suggestions on legislation addressing cross-
border data transfer.”
Regulatory Approaches to Cross-Border Data Transfers
, section 1: “Cross-border transfers of personal
information are increasingly common in today’s globalised economy. However, different jurisdictions
have different approaches to regulating such transfers.”
Cross-Border Data Transfer Requirements: Global Privacy Laws - Securiti
, section 1: “Data transfer
conditions, mechanisms, localization and regulatory authority of each law.”
The Regulation of Cross-Border Data Transfers in the Context … - Springer
, section 1: “No Party shall
prohibit or restrict the cross-border transfer of information, including personal information, by
electronic means if this activity is for the conduct of the business of a covered person.”
When configuring information systems for the communication and transport of personal data, an
organization should:
B
Explanation:
Reference: https://www.vonage.com/resources/articles/gdpr-means-customer-communications/
When configuring information systems for the communication and transport of personal data, an
organization should review configuration settings for compliance with privacy regulations and
standards. This means that the organization should ensure that the configuration settings are aligned
with the privacy principles and requirements that apply to the data being communicated or
transported, such as data minimization, purpose limitation, consent, encryption, pseudonymization,
anonymization, etc. The organization should also document and monitor the configuration settings
and perform regular audits and reviews to verify their effectiveness and compliance. Reference: :
CDPSE Review Manual (Digital Version), page 151
Which of the following helps define data retention time is a stream-fed data lake that includes
personal data?
B
Explanation:
A privacy impact assessment (PIA) is a systematic process of identifying and evaluating the potential
privacy risks and impacts of a data processing activity or system. A PIA helps to ensure that privacy is
considered and integrated into the design and development of data processing activities or systems,
and that privacy risks are mitigated or eliminated. A PIA also helps to determine the appropriate
retention periods for personal data based on the purpose and necessity of the data processing, as
well as the legal and regulatory obligations that apply to the data. Therefore, a PIA helps to define
data retention time in a stream-fed data lake that includes personal data. Reference: : CDPSE Review
Manual (Digital Version), page 99
When evaluating cloud-based services for backup, which of the following is MOST important to
consider from a privacy regulation standpoint?
B
Explanation:
Reference: https://www.isaca.org/resources/isaca-journal/past-issues/2014/selecting-the-right-
cloud-operating-model-privacy-and-data-security-in-the-cloud
When evaluating cloud-based services for backup, one of the most important factors to consider
from a privacy regulation standpoint is data residing in another country. This is because different
countries may have different privacy laws and regulations that apply to the personal data stored or
processed in their jurisdictions. Some countries may have more stringent or protective privacy laws
than others, while some countries may have more intrusive or invasive practices that pose threats to
data privacy. Therefore, an organization should be aware of the location of its cloud-based backup
service provider and its servers, and ensure that there are adequate safeguards and agreements in
place to protect the personal data from unauthorized or unlawful access, use, disclosure, or
transfer. Reference: : CDPSE Review Manual (Digital Version), page 159
Which of the following should be the FIRST consideration when selecting a data sanitization method?
D
Explanation:
The first consideration when selecting a data sanitization method is the type of storage device that
holds the data to be sanitized. Different types of storage devices have different characteristics and
limitations that affect the effectiveness and feasibility of data sanitization methods.
For example,
magnetic media, such as hard disk drives (HDDs), can be sanitized by data degaussing, which is
wiping data permanently by weakening the magnetic field1
.
However, data degaussing is not
applicable to devices that use solid state drive (SSD) technology, since SSDs do not store data
magnetically2
. Therefore, the storage type determines which data sanitization methods are suitable
and available for the data disposal process.
Reference:
ISACA, Why (and How to) Dispose of Digital Data, Data Degaussing1
ISACA, Best Practices for Data Hygiene, Data Hygiene Practices3
TechReset, Data Sanitization and Methods, Cryptographic Erasure2
Imperva, What is Data Sanitization?4
Which of the following system architectures BEST supports anonymity for data transmission?
D
Explanation:
A peer-to-peer (P2P) system architecture is a network model where each node (peer) can act as both
a client and a server, and communicate directly with other peers without relying on a centralized
authority or intermediary. A P2P system architecture best supports anonymity for data transmission,
by providing the following advantages:
It can hide the identity and location of the peers, by using encryption, pseudonyms, proxies, or onion
routing techniques, such as Tor1 or I2P2
. These techniques can prevent eavesdropping, tracking, or
censorship by third parties, such as Internet service providers, governments, or hackers.
It can distribute the data across multiple peers, by using hashing, replication, or fragmentation
techniques, such as BitTorrent3 or IPFS4
. These techniques can reduce the risk of data loss,
corruption, or tampering by malicious peers, and increase the availability and resilience of the data.
It can enable the peers to control their own data, by using consensus, validation, or incentive
mechanisms, such as blockchain5
or smart contracts. These mechanisms can ensure the integrity and
authenticity of the data transactions, and enforce the privacy policies and preferences of the data
owners.
Of the following, who should be PRIMARILY accountable for creating an organization’s privacy
management strategy?
D
Explanation:
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.
The chief privacy officer (CPO) is the senior executive who is responsible for establishing and
maintaining the organization’s privacy vision, strategy, and program. The CPO oversees the
development and implementation of privacy policies, procedures, standards, and controls, and
ensures that they align with the organization’s business objectives and legal obligations. The CPO
also leads the privacy governance structure, such as the privacy steering committee, and coordinates
with other stakeholders, such as the chief data officer (CDO), the information security steering
committee, and the legal counsel, to ensure that privacy is integrated into all aspects of the
organization’s operations. Reference: : CDPSE Review Manual (Digital Version), page 21