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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Privacy Operations and Lifecycle Management | 15% | - Data lifecycle controls
|
| Topic 2: Privacy Assessment and Audit Practices | 15% | - Reporting and follow-up
|
| Topic 3: Privacy Governance and Organization | 15% | - Privacy policies and procedures
|
| Topic 4: Privacy Frameworks and Standards | 20% | - DSCI Privacy Framework (DPF)
|
| Topic 5: Privacy Regulatory Compliance | 20% | - Key global and local regulations
|
| Topic 6: Privacy Risk Management | 15% | - Privacy risk identification and assessment
|
1. 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 and Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects. The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).
To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens.
The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.
Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.
What role can training and awareness play here? (250 to 500 words)
2. The assessor organization can issue the DSCI certification to the assessee organization if it is satisfied with the assessment outcome.
A) True
B) False
3. Following aspects can serve as inputs to a privacy organization for ensuring privacy protection:
I) Privacy related incidents detected/reported
II) Contractual obligations
III) Organization's exposure to personal information
IV) Regulatory requirements
A) I, II, III and IV
B) I, II and III
C) None of the above, as privacy and compliance protection mechanisms are evolved based only on organization's privacy policies and procedures
D) II and IV
4. Who is a Data Processor?
A) Entity that collects personal data
B) Entity that decides the means and purposes of processing
C) Entity that controls the data
D) Entity that acts on behalf of Data Fiduciary
5. Which of the following could be considered as triggers for updating privacy policy? (Choose all that apply.)
A) Privacy breach
B) Regulatory changes
C) Change in service provider for an established business process
D) Recruitment of more employees
Solutions:
| Question # 1 Answer: Only visible for members | Question # 2 Answer: B | Question # 3 Answer: A | Question # 4 Answer: D | Question # 5 Answer: A,B,C |
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