A new marketing application needs to use data from the organization's customer database. Prior to the application using the data, which of the following should be done FIRST?
Correct Answer: C
Explanation Before using data from the organization's customer database for a new marketing application, the first step should be to determine what data is required by the application and for what purpose. This will help to ensure that the data collection and processing are relevant, necessary, and proportionate to the intended use, and that the data minimization principle is followed. Data minimization means that only the minimum amount of personal data needed to achieve a specific purpose should be collected and processed, and that any excess or irrelevant data should be deleted or anonymized1. This will also help to comply with the data privacy laws and regulations that apply to the organization, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which require organizations to inform data subjects about the types and purposes of data processing, and to obtain their consent if needed23. References: ISACA, Data Privacy Audit/Assurance Program, Control Objective 2: Data Minimization, p. 61 ISACA, GDPR Data Protection Impact Assessments, p. 4-52 ISACA, CCPA vs. GDPR: Similarities and Differences, p. 1-23
Question 17
Which of the following should be done FIRST to address privacy risk when migrating customer relationship management (CRM) data to a new system?
Correct Answer: C
Explanation A privacy impact assessment (PIA) is a systematic process to identify and evaluate the potential privacy impacts of a system, project, program or initiative that involves the collection, use, disclosure or retention of personal data. A PIA should be done first to address privacy risk when migrating customer relationship management (CRM) data to a new system, as it would help to ensure that privacy risks are identified and mitigated before the migration is executed. A PIA would also help to ensure compliance with privacy principles, laws and regulations, and alignment with customer expectations and preferences. The other options are not as important as performing a PIA when addressing privacy risk when migrating CRM data to a new system. Developing a data migration plan is a process of defining and documenting the objectives, scope, approach, methods and steps for transferring data from one system to another, but it does not necessarily address privacy risk or impact. Conducting a legitimate interest analysis (LIA) is a process of assessing whether there is a legitimate interest for processing personal data that outweighs the rights and interests of the data subjects, but it is only applicable in certain jurisdictions and situations where legitimate interest is a valid legal basis for processing. Obtaining consent from data subjects is a process of obtaining their permission or agreement before collecting, using, disclosing or transferring their personal data for specific purposes, but it may not be required or sufficient for migrating CRM data to a new system, depending on the context and nature of the migration and the applicable laws and regulations1, p. 67 References: 1: CDPSE Review Manual (Digital Version)
Question 18
Which of the following would MOST effectively reduce the impact of a successful breach through a remote access solution?
Correct Answer: C
Question 19
Which of the following is an example of data anonymization as a means to protect personal data when sharing a database?
Correct Answer: D
Explanation Data anonymization is a method of protecting personal data by modifying or removing any information that can be used to identify an individual, either directly or indirectly, in a data set. Data anonymization aims to prevent the re-identification of the data subjects, even by the data controller or processor, or by using additional data sources or techniques. Data anonymization also helps to comply with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which require data controllers and processors to respect the privacy rights and preferences of the data subjects. The data is transformed such that re-identification is impossible is an example of data anonymization, as it involves applying irreversible techniques, such as aggregation, generalization, perturbation, or synthesis, to alter the original data in a way that preserves their utility and meaning, but eliminates their identifiability. For example, a database of customer transactions can be anonymized by replacing the names and addresses of the customers with random codes, and by adding noise or rounding to the amounts and dates of the transactions. The other options are not examples of data anonymization, but of other methods of protecting personal data that do not guarantee the impossibility of re-identification. The data is encrypted and a key is required to re-identify the data is an example of data pseudonymization, which is a method of replacing direct identifiers with pseudonyms, such as codes or tokens, that can be linked back to the original data with a key or algorithm. Data pseudonymization does not prevent re-identification by authorized parties who have access to the key or algorithm, or by unauthorized parties who can break or bypass the encryption. Key fields are hidden and unmasking is required to access to the data is an example of data masking, which is a method of concealing or obscuring sensitive data elements, such as names or credit card numbers, with characters, symbols or blanks. Data masking does not prevent re-identification by authorized parties who have permission to unmask the data, or by unauthorized parties who can infer or guess the hidden data from other sources or clues. Names and addresses are removed but the rest of the data is left untouched is an example of data deletion, which is a method of removing direct identifiers from a data set. Data deletion does not prevent re-identification by using indirect identifiers, such as age, gender, occupation or location, that can be combined or matched with other data sources to re-establish the identity of the data subjects. References: * Big Data Deidentification, Reidentification and Anonymization - ISACA, section 2: "Anonymization is the ability for the data controller to anonymize the data in a way that it is impossible for anyone to establish the identity of the data." * Data Anonymization - Overview, Techniques, Advantages, section 1: "Data anonymization is a method of ensuring that the company understands and enforces its duty to secure sensitive, personal, and confidential data in a world of highly complex data protection mandates that can vary depending on where the business and the customers are based."
Question 20
Which of the following is the MOST important consideration when choosing a method for data destruction?
Correct Answer: B
Validation and certification of data destruction is the most important consideration when choosing a method for data destruction, because it provides evidence that the data has been destroyed beyond recovery and that the organization has complied with the applicable information security frameworks and legal requirements. Validation and certification can also help to prevent data breaches, avoid legal liabilities, and enhance the organization's reputation and trustworthiness. Different methods of data destruction may have different levels of validation and certification, depending on the type of media, the sensitivity of the data, and the standards and guidelines followed. For example, some methods may require a third-party verification or audit, while others may generate a certificate of destruction or a report of erasure. Therefore, the organization should choose a method that can provide sufficient validation and certification for its specific needs and obligations. Reference: Secure Data Disposal and Destruction: 6 Methods to Follow, KirkpatrickPrice Data Destruction Standards and Guidelines, BitRaser Best Practices for Data Destruction, U.S. Department of Education
