IAPP CIPP-US Exam Dumps

SCENARIO Please use the following to answer the next QUESTION: You are the chief privacy officer at HealthCo, a major hospital in a large U.S. city in state A. HealthCo is a HIPAA-covered entity that provides healthcare services to more than 100,000 patients. A third-party cloud computing service provider, CloudHealth, stores and manages the electronic protected health information (ePHI) of these individuals on behalf of HealthCo. CloudHealth stores the data in state B. As part of HealthCo’s business associate agreement (BAA) with CloudHealth, HealthCo requires CloudHealth to implement security measures, including industry standard encryption practices, to adequately protect the data. However, HealthCo did not perform due diligence on CloudHealth before entering the contract, and has not conducted audits of CloudHealth’s security measures. A CloudHealth employee has recently become the victim of a phishing attack. When the employee unintentionally clicked on a link from a suspicious email, the PHI of more than 10,000 HealthCo patients was compromised. It has since been published online. The HealthCo cybersecurity team quickly identifies the perpetrator as a known hacker who has launched similar attacks on other hospitals – ones that exposed the PHI of public figures including celebrities and politicians. During the course of its investigation, HealthCo discovers that CloudHealth has not encrypted the PHI in accordance with the terms of its contract. In addition, CloudHealth has not provided privacy or security training to its employees. Law enforcement has requested that HealthCo provide its investigative report of the breach and a copy of the PHI of the individuals affected. A patient affected by the breach then sues HealthCo, claiming that the company did not adequately protect the individual’s ePHI, and that he has suffered substantial harm as a result of the exposed data. The patient’s attorney has submitted a discovery request for the ePHI exposed in the breach. Of the safeguards required by the HIPAA Security Rule, which of the following is NOT at issue due to HealthCo’s actions? 

SCENARIO Please use the following to answer the next QUESTION: A US-based startup company is selling a new gaming application. One day, the CEO of the company receives an urgent letter from a prominent EU-based retail partner. Triggered by an unresolved complaint lodged by an EU resident, the letter describes an ongoing investigation by a supervisory authority into the retailer’s data handling practices. The complainant accuses the retailer of improperly disclosing her personal data, without consent, to parties in the United States. Further, the complainant accuses the EU-based retailer of failing to respond to her withdrawal of consent and request for erasure of her personal data. Your organization, the US-based startup company, was never informed of this request for erasure by the EUbased retail partner. The supervisory authority investigating the complaint has threatened the suspension of data flows if the parties involved do not cooperate with the investigation. The letter closes with an urgent request: “Please act immediately by identifying all personal data received from our company.” This is an important partnership. Company executives know that its biggest fans come from Western Europe; and this retailer is primarily responsible for the startup’s rapid market penetration. As the Company’s data privacy leader, you are sensitive to the criticality of the relationship with the retailer. Under the General Data Protection Regulation (GDPR), how would the U.S.-based startup company most likely be classified? 

Sarah lives in San Francisco, California. Based on a dramatic increase in unsolicited commercial emails, Sarah believes that a major social media platform with over 50 million users has collected a lot of personal information about her. The company that runs the platform is based in New York and France. Why is Sarah entitled to ask the social media platform to delete the personal information they have collected about her? 

Which of the following laws is NOT involved in the regulation of employee background checks?

Which of the following is commonly required for an entity to be subject to breach notification requirements under most state laws? 

Which of the following became the first state to pass a law specifically regulating the practices of data brokers?

Which of the following is NOT one of three broad categories of products offered by data brokers, as identified by the U.S. Federal Trade Commission (FTC)? 

According to FERPA, when can a school disclose records without a student’s consent?

Smith Memorial Healthcare (SMH) is a hospital network headquartered in New York and operating in 7 other states. SMH uses an electronic medical record to enter and track information about its patients. Recently, SMH suffered a data breach where a third-party hacker was able to gain access to the SMH internal network. Because it is a HIPPA-covered entity, SMH made a notification to the Office of Civil Rights at the U.S. Department of Health and Human Services about the breach. Which statement accurately describes SMH’s notification responsibilities? 

What is a legal document approved by a judge that formalizes an agreement between a governmental agency and an adverse party called? 

Which is an exception to the general prohibitions on telephone monitoring that exist under the U.S. Wiretap Act? 

A large online bookseller decides to contract with a vendor to manage Personal Information (PI). What is the least important factor for the company to consider when selecting the vendor?

SCENARIO Please use the following to answer the next QUESTION Noah is trying to get a new job involving the management of money. He has a poor personal credit rating, but he has made better financial decisions in the past two years. One potential employer, Arnie’s Emporium, recently called to tell Noah he did not get a position. As part of the application process, Noah signed a consent form allowing the employer to request his credit report from a consumer reporting agency (CRA). Noah thinks that the report hurt his chances, but believes that he may not ever know whether it was his credit that cost him the job. However, Noah is somewhat relieved that he was not offered this particular position. He noticed that the store where he interviewed was extremely disorganized. He imagines that his credit report could still be sitting in the office, unsecured. Two days ago, Noah got another interview for a position at Sam’s Market. The interviewer told Noah that his credit report would be a factor in the hiring decision. Noah was surprised because he had not seen anything on paper about this when he applied. Regardless, the effect of Noah’s credit on his employability troubles him, especially since he has tried so hard to improve it. Noah made his worst financial decisions fifteen years ago, and they led to bankruptcy. These were decisions he made as a young man, and most of his debt at the time consisted of student loans, credit card debt, and a few unpaid bills – all of which Noah is still working to pay off. He often laments that decisions he made fifteen years ago are still affecting him today. In addition, Noah feels that an experience investing with a large bank may have contributed to his financial troubles. In 2007, in an effort to earn money to help pay off his debt, Noah talked to a customer service representative at a large investment company who urged him to purchase stocks. Without understanding the risks, Noah agreed. Unfortunately, Noah lost a great deal of money. After losing the money, Noah was a customer of another financial institution that suffered a large security breach. Noah was one of millions of customers whose personal information was compromised. He wonders if he may have been a victim of identity theft and whether this may have negatively affected his credit. Noah hopes that he will soon be able to put these challenges behind him, build excellent credit, and find the perfect job. Consumers today are most likely protected from situations like the one Noah had buying stock because of which federal action or legislation?

SCENARIO Please use the following to answer the next QUESTION: Cheryl is the sole owner of Fitness Coach, Inc., a medium-sized company that helps individuals realize their physical fitness goals through classes, individual instruction, and access to an extensive indoor gym. She has owned the company for ten years and has always been concerned about protecting customer’s privacy while maintaining the highest level of service. She is proud that she has built long-lasting customer relationships. Although Cheryl and her staff have tried to make privacy protection a priority, the company has no formal privacy policy. So Cheryl hired Janice, a privacy professional, to help her develop one. After an initial assessment, Janice created a first of a new policy. Cheryl read through the draft and was concerned about the many changes the policy would bring throughout the company. For example, the draft policy stipulates that a customer’s personal information can only be held for one year after paying for a service such as a session with personal trainer. It also promises that customer information will not be shared with third parties without the written consent of the customer. The wording of these rules worry Cheryl since stored personal information often helps her company to serve her customers, even if there are long pauses between their visits. In addition, there are some third parties that provide crucial services, such as aerobics instructors who teach classes on a contract basis. Having access to customer files and understanding the fitness levels of their students helps instructors to organize their classes. Janice understood Cheryl’s concerns and was already formulating some ideas for revision. She tried to put Cheryl at ease by pointing out that customer data can still be kept, but that it should be classified according to levels of sensitivity. However, Cheryl was skeptical. It seemed that classifying data and treating each type differently would cause undue difficulties in the company’s day-to-day operations. Cheryl wants one simple data storage and access system that any employee can access if needed. Even though the privacy policy was only a draft, she was beginning to see that changes within her company were going to be necessary. She told Janice that she would be more comfortable with implementing the new policy gradually over a period of several months, one department at a time. She was also interested in a layered approach by creating documents listing applicable parts of the new policy for each department. What is the main problem with Cheryl’s suggested method of communicating the new privacy policy? 

The CFO of a pharmaceutical company is duped by a phishing email and discloses many of the company’s employee personnel files to an online predator. The files include employee contact information, job applications, performance reviews, discipline records, and job descriptions. Which of the following state laws would be an affected employee’s best recourse against the employer? 

If an organization certified under Privacy Shield wants to transfer personal data to a third party acting as an agent, the organization must ensure the third party does all of the following EXCEPT? 

Which was NOT one of the five priority areas listed by the Federal Trade Commission in its 2012 report, “Protecting Consumer Privacy in an Era of Rapid Change: Recommendations for Businesses and Policymakers”? 

Which of the following best describes an employer’s privacy-related responsibilities to an employee who has left the workplace? 

When developing a company privacy program, which of the following relationships will most help a privacy professional develop useful guidance for the organization?

When may a financial institution share consumer information with non-affiliated third parties for marketing purposes? 

SuperMart is a large Nevada-based business that has recently determined it sells what constitutes “covered information” under Nevada’s privacy law, Senate Bill 260. Which of the following privacy compliance steps would best help SuperMart comply with the law?

What consumer protection did the Fair and Accurate Credit Transactions Act (FACTA) require? 

SCENARIO Please use the following to answer the next QUESTION When there was a data breach involving customer personal and financial information at a large retail store, the company’s directors were shocked. However, Roberta, a privacy analyst at the company and a victim of identity theft herself, was not. Prior to the breach, she had been working on a privacy program report for the executives. How the company shared and handled data across its organization was a major concern. There were neither adequate rules about access to customer information nor procedures for purging and destroying outdated data. In her research, Roberta had discovered that even low- level employees had access to all of the company’s customer data, including financial records, and that the company still had in its possession obsolete customer data going back to the 1980s. Her report recommended three main reforms. First, permit access on an as-needs-to-know basis. This would mean restricting employees’ access to customer information to data that was relevant to the work performed. Second, create a highly secure database for storing customers’ financial information (e.g., credit card and bank account numbers) separate from less sensitive information. Third, identify outdated customer information and then develop a process for securely disposing of it. When the breach occurred, the company’s executives called Roberta to a meeting where she presented the recommendations in her report. She explained that the company having a national customer base meant it would have to ensure that it complied with all relevant state breach notification laws. Thanks to Roberta’s guidance, the company was able to notify customers quickly and within the specific timeframes set by state breach notification laws. Soon after, the executives approved the changes to the privacy program that Roberta recommended in her report. The privacy program is far more effective now because of these changes and, also, because privacy and security are now considered the responsibility of every employee. Based on the problems with the company’s privacy security that Roberta identifies, what is the most likely cause of the breach? 

Under the Telemarketing Sales Rule, what characteristics of consent must be in place for an organization to acquire an exception to the Do-Not-Call rules for a particular consumer? 

California’s SB 1386 was the first law of its type in the United States to do what?