CIPT Exam Question 71

SCENARIO
WebTracker Limited is a cloud-based online marketing service located in London. Last year, WebTracker migrated its IT infrastructure to the cloud provider AmaZure, which provides SQL Databases and Artificial Intelligence services to WebTracker. The roles and responsibilities between the two companies have been formalized in a standard contract, which includes allocating the role of data controller to WebTracker.
The CEO of WebTracker, Mr. Bond, would like to assess the effectiveness of AmaZure's privacy controls, and he recently decided to hire you as an independent auditor. The scope of the engagement is limited only to the marketing services provided by WebTracker, you will not be evaluating any internal data processing activity, such as HR or Payroll.
This ad-hoc audit was triggered due to a future partnership between WebTracker and SmartHome - a partnership that will not require any data sharing. SmartHome is based in the USA, and most recently has dedicated substantial resources to developing smart refrigerators that can suggest the recommended daily calorie intake based on DNA information. This and other personal data is collected by WebTracker.
To get an idea of the scope of work involved, you have decided to start reviewing the company's documentation and interviewing key staff to understand potential privacy risks.
The results of this initial work include the following notes:
* There are several typos in the current privacy notice of WebTracker, and you were not able to find the privacy notice for SmartHome.
* You were unable to identify all the sub-processors working for SmartHome. No subcontractor is indicated in the cloud agreement with AmaZure, which is responsible for the support and maintenance of the cloud infrastructure.
* There are data flows representing personal data being collected from the internal employees of WebTracker, including an interface from the HR system.
* Part of the DNA data collected by WebTracker was from employees, as this was a prototype approved by the CEO of WebTracker.
* All the WebTracker and SmartHome customers are based in USA and Canada.
Which of the following issues is most likely to require an investigation by the Chief Privacy Officer (CPO) of WebTracker?
  • CIPT Exam Question 72

    Why is first-party web tracking very difficult to prevent?
  • CIPT Exam Question 73

    SCENARIO
    It should be the most secure location housing data in all of Europe, if not the world. The Global Finance Data Collective (GFDC) stores financial information and other types of client data from large banks, insurance companies, multinational corporations and governmental agencies. After a long climb on a mountain road that leads only to the facility, you arrive at the security booth. Your credentials are checked and checked again by the guard to visually verify that you are the person pictured on your passport and national identification card.
    You are led down a long corridor with server rooms on each side, secured by combination locks built into the doors. You climb a flight of stairs and are led into an office that is lighted brilliantly by skylights where the GFDC Director of Security, Dr. Monique Batch, greets you. On the far wall you notice a bank of video screens showing different rooms in the facility. At the far end, several screens show different sections of the road up the mountain Dr. Batch explains once again your mission. As a data security auditor and consultant, it is a dream assignment: The GFDC does not want simply adequate controls, but the best and most effective security that current technologies allow.
    "We were hacked twice last year," Dr. Batch says, "and although only a small number of records were stolen, the bad press impacted our business. Our clients count on us to provide security that is nothing short of impenetrable and to do so quietly. We hope to never make the news again." She notes that it is also essential that the facility is in compliance with all relevant security regulations and standards.
    You have been asked to verify compliance as well as to evaluate all current security controls and security measures, including data encryption methods, authentication controls and the safest methods for transferring data into and out of the facility. As you prepare to begin your analysis, you find yourself considering an intriguing question: Can these people be sure that I am who I say I am?
    You are shown to the office made available to you and are provided with system login information, including the name of the wireless network and a wireless key. Still pondering, you attempt to pull up the facility's wireless network, but no networks appear in the wireless list. When you search for the wireless network by name, however it is readily found.
    Why would you recommend that GFC use record encryption rather than disk, file or table encryption?
  • CIPT Exam Question 74

    What is true of providers of wireless technology?
  • CIPT Exam Question 75

    SCENARIO
    Looking back at your first two years as the Director of Personal Information Protection and Compliance for the Berry Country Regional Medical Center in Thorn Bay, Ontario, Canada, you see a parade of accomplishments, from developing state-of-the-art simulation based training for employees on privacy protection to establishing an interactive medical records system that is accessible by patients as well as by the medical personnel. Now, however, a question you have put off looms large: how do we manage all the data-not only records produced recently, but those still on hand from years ago? A data flow diagram generated last year shows multiple servers, databases, and work stations, many of which hold files that have not yet been incorporated into the new records system. While most of this data is encrypted, its persistence may pose security and compliance concerns. The situation is further complicated by several long-term studies being conducted by the medical staff using patient information. Having recently reviewed the major Canadian privacy regulations, you want to make certain that the medical center is observing them.
    You also recall a recent visit to the Records Storage Section, often termed "The Dungeon" in the basement of the old hospital next to the modern facility, where you noticed a multitude of paper records. Some of these were in crates marked by years, medical condition or alphabetically by patient name, while others were in undifferentiated bundles on shelves and on the floor. The back shelves of the section housed data tapes and old hard drives that were often unlabeled but appeared to be years old. On your way out of the dungeon, you noticed just ahead of you a small man in a lab coat who you did not recognize. He carried a batch of folders under his arm, apparently records he had removed from storage.
    Which data lifecycle phase needs the most attention at this Ontario medical center?