BEST Verified DSCI DCPLA Exam Questions (2023)
The Best Practice Test Preparation for the DCPLA Certification Exam
NEW QUESTION 42
FILL BLANK
IUA and PAT
The company has a very mature enterprise level access control policy to restrict access to information. There is a single sign-on platform available to access company resources such as email, intranet, servers, etc. However, the access policy in client relationships varies depending on the client requirements. In fact, in many cases clients provide access ids to the employees of the company and manage them. Some clients also put technical controls to limit access to information such data masking tool, encryption, and anonymizing data, among others. Some clients also record the data collection process to monitor if the employee of the company does not collect more data than is required. Taking cue from the best practices implemented by the clients, the company, through the consultants, thought of realigning its access control policy to include control on data collection and data usage by the business functions and associated third parties. As a first step, the consultants advised the company to start monitoring the PI collection, usage and access by business functions without their knowledge. The IT function was given the responsibility to do the monitoring, as majority of the information was handled electronically. The analysis showed that many times, more information than necessary was collected by the some functions, however, no instances of misuse could be identified.
After few days of this exercise, a complaint was registered by a female company employee in the HR function against a male employee in IT support function. The female employee accused the male employee of accessing her photographs stored on a shared drive and posting it on a social networking site.
(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 & 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.
What role can training and awareness play here? (250 to 500 words)
Answer:
Explanation:
Training and awareness play an essential role in the successful implementation of a comprehensive privacy program. This is especially true for an organization that has limited expertise on the subject. Training and awareness help to ensure that everyone understands their obligations under the EU GDPR as well as other applicable laws and regulations, while also providing employees with best practices to ensure data protection.
One way to ensure optimal training and awareness is by creating a comprehensive training curriculum tailored specifically for XYZ's needs. The curriculum should cover topics such as data privacy rights, compliance requirements, impact assessment, access control measures, encryption technologies, incident response plans and more. Additionally, it should be augmented with practical examples so that employees can understand how these principles apply in different scenarios.
Moreover, a comprehensive awareness program should be established to keep all employees informed of the latest developments in privacy law. This can include newsletters, webinars and other communications that explain changes in laws or policies, provide information on new technologies, or even give advice on how to handle particular challenges.
Finally, management should ensure that there are measures in place to evaluate the effectiveness of the training and awareness programs. This can include surveys, interviews with staff members and other methods such as focus groups or workshops. All these means will help XYZ assess whether its employees understand their obligations under the GDPR and other applicable laws and regulations.
By creating a comprehensive training curriculum tailored specifically for its needs and establishing an effective awareness program, XYZ can ensure that everyone in the organization is better informed and aware of their responsibilities under the GDPR. This, in turn, will help to improve compliance with the applicable laws and regulations while protecting its customers' data. Ultimately, this will allow the company to realize its full potential on the European market.
By investing in training and awareness programs, XYZ demonstrates a commitment to proper privacy procedures which will not only benefit its operations in Europe but also those in the US. It is essential for any company operating today to prioritize privacy so that it can build client trust as well as remain compliant with regulations. With an effective training and awareness program in place, XYZ can confidently approach both current and potential clients knowing that their data will be secure.
Overall, training and awareness are important components of a successful privacy program. By investing in these programs, XYZ can ensure that everyone is informed and aware of their responsibilities under the GDPR and other applicable laws and regulations. This, in turn, will help to protect customer data while also improving compliance with applicable laws. Ultimately, this will help XYZ realize its full potential on the European market as well as build client trust.
By establishing a comprehensive training and awareness program, XYZ will be better prepared to handle the challenges of data privacy regulation. With the proper methods in place, the company can not only protect its customers' data but also remain compliant with laws and regulations. This, in turn, will help it achieve success on both domestic and international markets. Ultimately, investing in training and awareness is essential for any organization operating today.
NEW QUESTION 43
______________ is used to identify and reduce privacy risks by analyzing what is processed by the entity and the policies in place to protect the data.
- A. Anonymization
- B. Threat Hunting
- C. Minimization
- D. Privacy Impact Assessment
Answer: D
NEW QUESTION 44
Which of the following are key contributors that would enhance the complexity in implementing security measures for protection of personal information? (Choose all that apply.)
- A. Data collection through multiple modes and channels
- B. Regulatory requirements to issue privacy notice and data breach notification in specified format
- C. Evolution of nimble and flexible business processes affecting access management
- D. None of the above
Answer: A,B,C
NEW QUESTION 45
Which of the following measures can an organization implement to establish regulatory compliance intelligence? (Choose all that apply.)
- A. Establish a process that keeps a track of applicable legal and regulatory changes
- B. Ensure that knowledge with respect to legal and regulatory compliances is managed effectively
- C. Ensure that a mechanism exists for quick and effective provisioning, de-provisioning and authorization of access to information or systems which are exposed to data
- D. Identify the liabilities imposed by the regulations with respect to specific data elements
Answer: A,D
NEW QUESTION 46
The assessor organization can issue the DSCI certification to the assessee organization if it is satisfied with the assessment outcome.
- A. True
- B. False
Answer: A
NEW QUESTION 47
FILL BLANK
MIM
The company has a well-defined and tested Information security monitoring and incident management process in place. The process has been in place since last 10 years and has matured significantly over a period of time.
There is a Security Operations Centre (SOC) to detect security incidents based on well-defined business rules.
The security incident management is based on ISO 27001 and defines incident types, alert levels, roles and responsibilities, escalation matrix, among others. The consultants advised company to realign the existing monitoring and incident management to cater to privacy requirements. The company consultants sought help of external privacy expert in this regard.
(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 & 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.
If you were the privacy expert advising the company, what steps would you suggest to realign the existing security monitoring and incident management to address privacy requirements especially those specific to client relationships? (250 to 500 words)
Answer:
Explanation:
As an external privacy expert, the first step I would suggest for XYZ company is to conduct a detailed assessment of their existing security monitoring and incident management processes. This should include an analysis of how data is collected, stored, and accessed; what kind of policies are currently in place; and any other relevant security measures. It should also identify areas where additional process or technical changes may be required to meet privacy requirements.
Once the initial assessment has been completed, I would recommend that XYZ take steps to ensure that its processes align with applicable laws and regulations regarding data protection, such as EU GDPR. For example, they should update their policies around data collection and storage so that they comply with GDPR's requirements on consent and purpose limitation. Additionally, XYZ should ensure that their systems are secure and only authorized personnel can access the data.
Also I would suggest that XYZ develop a comprehensive incident response plan, indicating how they will address any data breaches or other privacy incidents. The plan should include steps for notification to affected individuals or organizations, containment of the incident, investigations into its cause and scope, and remediation efforts to prevent similar incidents in the future.
Lastly I would recommend that XYZ review their client contracts to ensure that they clearly describe the company's commitments regarding data protection and security measures. This could include GDPR-compliant language on consent forms as well as clauses committing to regularly audit and update processes as necessary. These contractual terms will help protect both XYZ and their clients in the event of a privacy breach.
In conclusion, implementing these steps will help XYZ establish an effective privacy program that meets all applicable legal requirements, protects their clients' data, and provides them with a competitive edge in the market. Additionally, it will ensure that they remain compliant and have appropriate measures in place to address any potential issues. By taking these proactive measures now, XYZ can ensure that they continue to successfully operate in both the EU and US markets while protecting the privacy of its customers.
NEW QUESTION 48
Which of the following parameters should ideally be addressed by a privacy program of an organization?
(Choose all that apply.)
- A. Privacy incident response plan and grievance handling
- B. Training and data classification
- C. Intellectual Property (IP) protection
- D. Environmental security concerns
Answer: A,B
NEW QUESTION 49
With respect to privacy implementation, organizations should strive for which of the following:
- A. Demonstrable accountability
- B. Meaningful compliance
- C. None of the above
- D. Checklist based exercise
Answer: B
NEW QUESTION 50
As a privacy assessor, what would most likely be the first artefact you would ask for while assessing an organization which claims that it has implemented a privacy program?
- A. Records of privacy specific training imparted to the employees handling personal information
- B. Privacy risk management framework
- C. Personal information management policy
- D. Records of deployed privacy notices and statements
Answer: B
NEW QUESTION 51
FILL BLANK
VPI
As a starting point, the consultants undertook a visibility exercise to understand the type of personal information (PI) being dealt with within the organization and also by third parties and the scope was to cover all the client relationships (IT services and BPM both) and functions. They met with the client relationship and business function owners to collect this data. The consultants did a mapping exercise to identify PI and associated attributes including whether company directly collects the PI, how it is accessed, transmitted, stored and what are the applicable regulatory and contractual requirements. Given the enormous scale of the exercise (enterprise wide), the consultant classified the PI as financial information, health related information, personally identifiable information, etc. and collected the rest of the attributes against this classification. When understanding the underlying technology environment, the consultants restricted themselves only to the technology environment that was under company's ownership and premises and did not continue the exercise for client side environment. This was done because relationship owners seemed reluctant to share such client specific details. Only in 2 relationships, were the relationship heads proactive to introduce the consultants to the clients and get the requisite information. The analysis of the environment in these 2 relationships revealed that even though lots of restrictions were imposed at the company side, the same restrictions were not available at the client side.
Many business functions were also availing services from third party service providers. Though these functions were aware of the type of PI dealt by third parties, they were not aware of the technology environment at the third parties. In one odd case, personal information of a company employee was accidentally leaked by the employee of the third party through the social networking site. The consultants relied on whatever information was provided by the functions w.r.t. third parties. After finishing the data collection, the consultant used the information to create information flow maps highlighting the flow of information across systems deployed at the company premises. This work helped them have a high level view of PI dealt by the company. The data collection exercise has been conducted only once by the consultants. The visibility exercise empowered the management to have a company-wide view of PI and how it flows across the organization. This information was coupled with the security controls / practices deployed at the relationship or function level to derive the risk posture of the PI.
(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 & 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.
Was the visibility exercise adequately carried out? What gaps did you notice? (250 to 500 words)
Answer:
Explanation:
The consultants appointed by XYZ to design and implement the enterprise wide privacy program conducted a visibility exercise. This exercise was meant to capture the current state of Personal Information (PI) flows within the organization, identify any gaps between existing security controls/practices and intended enterprise-wide PI practices. The visibility exercise also included mapping the legal obligations of the organization in protecting PI across different jurisdictions where its operations were spread. Though this exercise seemed adequate to start with, some gaps in terms of meeting the requirements of EU GDPR were noticed during course of implementation.
Firstly, though the visibility exercise covered all channels through which PI would flow in and out of an organization - like email accounts, websites and physical storage locations etc., it did not cover every element of PI such as Social Security numbers and financial data. Moreover, there was no comprehensive assessment on the technical feasibility and costs associated with implementing additional measures for protecting this information. This could have been done in order to ensure that any new systems or processes introduced met the technical requirements of GDPR.
Additionally, there were certain gaps in terms of external service providers who are also responsible for ensuring compliance with GDPR while processing/storing personal data on behalf of XYZ. Though XYZ had ensured that all its existing contracts contained provisions regarding compliance with legal requirements related to privacy and confidentiality, it did not carry out any due diligence exercise to ascertain whether these third-party service providers had adequate security practices in place to comply with GDPR regulations.
Lastly, the visibility exercise did not cover all the legal obligations of XYZ in terms of compliance with GDPR. For instance, it did not consider any potential liabilities arising from data breaches and the process for dealing with such eventualities. Nor was any process put in place to ensure that appropriate technical and organizational measures were taken to protect PI as required by GDPR.
Thus though the visibility exercise carried out by XYZ consultants seemed adequate at first glance, there were several gaps identified in terms of meeting EU's GDPR requirements. These gaps could have been addressed through a more comprehensive assessment and must be taken care of if XYZ has to realize its full potential in Europe. As GDPR is now firmly in place across the continent, companies cannot ignore its regulations and must take necessary action to ensure compliance.
This includes making sure that every element of PI is taken into consideration while designing an enterprise-wide privacy program, due diligence with regards to external service providers who process/store data on behalf of XYZ, and establishing a comprehensive legal framework for dealing with any potential liabilities arising from data breaches. In short, if XYZ does not address these gaps effectively, it may find itself in a vulnerable position in terms of protecting personal information as required by applicable laws. It will also be at risk of facing significant fines or other penalties.
NEW QUESTION 52
From the following list, identify the technology aspects that are specially designed for upholding privacy:
I) Data minimization
II) Intrusion prevention system
III) Data scrambling
IV) Data loss prevention
V) Data portability
VI) Data obfuscation
VII) Data encryption
VIII) Data mirroring
- A. Only I, III, IV, VI and VII
- B. Only I, II, III, VII and VIII
- C. Only II, V, VI, VII and VIII
- D. Only I, III, V, VII and VIII
Answer: A
NEW QUESTION 53
Which of the following could be considered as triggers for updating privacy policy? (Choose all that apply.)
- A. Privacy breach
- B. Regulatory changes
- C. Recruitment of more employees
- D. Change in service provider for an established business process
Answer: A,B
NEW QUESTION 54
FILL BLANK
RCI and PCM
Given its global operations, the company is exposed to multiple regulations (privacy related) across the globe and needs to comply mostly through contracts for client relationships and directly for business functions. The corporate legal team is responsible for managing the contracts and understanding, interpreting and translating the legal requirements. There is no formal tracking of regulations done. The knowledge about regulations mainly comes through interaction with the client team. In most of the contracts, the clients have simply referred to the applicable legislations without going any further in terms of their applicability and impact on the company. Since business expansion is the priority, the contracts have been signed by the company without fully understanding their applicability and impact. Incidentally, when the privacy initiatives were being rolled out, a major data breach occurred at one of the healthcare clients located in the US. The US state data protection legislation required the client to notify the data breach. During investigations, it emerged that the data breach happened because of some vulnerability in the system owned by the client but managed by the company and the breach actually happened 5 months back and came to notice now. The system was used to maintain medical records of the patients. This vulnerability had been earlier identified by a third party vulnerability assessment of the system and the closure of vulnerability was assigned to the company. The company had made the requisite changes and informed the client. The client, however, was of the view that the changes were actually not made by the company and they therefore violated the terms of contract which stated that - "the company shall deploy appropriate organizational and technology measures for protection of personal information in compliance with the XX state data protection legislation." The company could not produce necessary evidences to prove that the configuration changes were actually made by it (including when these were made).
(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 & 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.
What should be the learning for the company going forward? What should the consultants suggest? (250 to 500 words)
Answer:
Explanation:
The consultants should suggest a comprehensive and integrated privacy program for the company which addresses the current regulatory requirements while being proactive in anticipating any changes to these regulations. The program should be effective, flexible, cost-efficient and easy to understand & implement.
To begin with, the program should involve an assessment of all existing processes and procedures that are related to personal data processing in order to identify potential areas of risk. The potential risks along with recommended mitigating controls should then be documented in a Privacy Impact Assessment (PIA) report.
This will enable the organization to assess its compliance level against applicable regulations.
It is also important for XYZ to have strong Data Governance policies & procedures along with appropriate organizational structures and accountability mechanisms in place. This will include a Data Privacy Officer (DPO) who is responsible for overseeing the compliance program and being the point of contact for data protection supervisory authorities. The DPO should be part of the management team and report to the CIO's office as well as senior-level executives.
A consultant should also recommend data minimization, pseudonymization, encryption, and other security measures to protect personal information. In addition, they can recommend regular privacy awareness training sessions for employees, so that they are up-to-date on changes in regulations and understand how their role impacts data privacy and security. Lastly, all systems & processes should be monitored & audited to ensure compliance with relevant regulations.
As a result, consultants should provide clients in the EU and US with an integrated & comprehensive privacy program that provides the necessary assurances and protects sensitive data from unauthorized access or misuse. By leveraging outsourcing opportunities in the healthcare sector in the US, XYZ could potentially gain competitive advantage.
NEW QUESTION 55
XYZ bank has recently decided to start offering online banking services. For doing so, the bank has outsourced its IT operations and processes to various third parties. Acknowledging privacy concerns, bank has decided to implement a privacy program. Assuming you have been tasked to deploy this framework for the bank, which of the following would most likely be your first step?
- A. Ensure that bank is equipped to test the relevance of each legal and compliance requirement in its environment
- B. None of the above
- C. Assign privacy roles and responsibilities for process owners
- D. Create an inventory of business processes that deal with personal information and identify the associated data element
Answer: D
NEW QUESTION 56
Certification once granted, will be valid for period of _______ years subject to surveillance assessments.
- A. 0
- B. 1
- C. 2
- D. 3
Answer: C
NEW QUESTION 57
Categorize the following statements as: Visibility/ Capability /Enforcement /Demonstration Problems
"The network is unable to restrict unwanted external connections carrying sensitive information."
- A. Enforcement
- B. Capability
- C. Visibility
- D. Demonstration
Answer: B
NEW QUESTION 58
An entity shall retain personal data only as long as may be reasonably necessary to satisfy the purpose for which it is processed; or with respect to an established retention period. This privacy principle is known as?
- A. Use Limitation
- B. Collection Limitation
- C. Storage Limitation
- D. Security safeguards
Answer: C
NEW QUESTION 59
What is a Data Subject? (Choose all that apply.)
- A. An individual who collects data from illegitimate sources
- B. A company providing PI of its employees for processing
- C. An individual whose data/information is processed
- D. An individual who processes the data/information of individuals for providing necessary services
- E. An individual who provides his/her data/information for availing any service
Answer: C,E
NEW QUESTION 60
FILL BLANK
IUA and PAT
The company has a very mature enterprise level access control policy to restrict access to information. There is a single sign-on platform available to access company resources such as email, intranet, servers, etc. However, the access policy in client relationships varies depending on the client requirements. In fact, in many cases clients provide access ids to the employees of the company and manage them. Some clients also put technical controls to limit access to information such data masking tool, encryption, and anonymizing data, among others. Some clients also record the data collection process to monitor if the employee of the company does not collect more data than is required. Taking cue from the best practices implemented by the clients, the company, through the consultants, thought of realigning its access control policy to include control on data collection and data usage by the business functions and associated third parties. As a first step, the consultants advised the company to start monitoring the PI collection, usage and access by business functions without their knowledge. The IT function was given the responsibility to do the monitoring, as majority of the information was handled electronically. The analysis showed that many times, more information than necessary was collected by the some functions, however, no instances of misuse could be identified. After few days of this exercise, a complaint was registered by a female company employee in the HR function against a male employee in IT support function. The female employee accused the male employee of accessing her photographs stored on a shared drive and posting it on a social networking site.
(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 & 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.
What should the company do to limit data collection and usage and at the same time ensure that such kinds of incidents don't reoccur? (250 to 500 words)
Answer:
Explanation:
XYZ should strive to create a comprehensive privacy policy that addresses all aspects of data collection, usage and storage. This will both protect the company from legal liabilities as well as create an environment of trust between customers and the organization. It should also ensure that proper security controls are in place for both on-premise systems as well as cloud services. The policy should outline details regarding access privileges and procedures for handling sensitive personal information including photographs.
Further, XYZ should conduct regular training sessions with employees, especially those in IT support functions, to enhance their knowledge about the company's privacy policies and procedures. An employee code of conduct outlining restrictions on the misuse of data must be implemented and communicated clearly to all stakeholders involved in data processing activities. The company should also implement technical measures such as encryption and pseudonymisation of data, which will ensure that the data is only accessible by authorized personnel with proper privileges.
In addition to this, XYZ should also create a framework for breach notification that outlines the steps to be taken in case of any unauthorized access or disclosure of information. The policy should set out procedures for assessing incidents and for informing the relevant authorities as well as affected individuals within a specified timeframe. Finally, XYZ should develop an independent monitoring mechanism to ensure compliance with its privacy policies and procedures. This may include third-party audits, regular evaluation of existing policies, and periodic reviews of employee performance.
By investing in privacy and security controls at both procedural and technical levels, XYZ can ensure that it is able to keep pace with the ever-evolving privacy landscape and provide its customers with the assurance they need.
This will also help the company meet any new regulatory requirements as well as ensure that similar incidents don't reoccur in the future. In this way, XYZ will be able to successfully access and tap into potential markets while reducing legal liabilities associated with data misuse.
The bottom line is that proper investment in privacy and security will yield long-term dividends by enhancing customer trust in the organization. By implementing a comprehensive framework of policies, procedures and technical measures, XYZ can protect personal information from unauthorized access or disclosure, thereby providing increased assurance to customers that their data is safe and secure.
In this way, the company will be better positioned to remain competitive in an increasingly competitive landscape.
NEW QUESTION 61
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