CIPM practice question 1 of 30

SCENARIO Please use the following to answer the next QUESTIO N: As the Director of data protection for Consolidated Records Corporation, you are…

Choose your answer, then check it against the explanation.

Domain Privacy Program Operational Life Cycle

SCENARIO Please use the following to answer the next QUESTIO N: As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development. You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change. Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place. Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective. You are left contemplating: What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success? What are the next action steps? What process could most effectively be used to add privacy protections to a new, comprehensive program being developed at Consolidated?

Answer options

Correct Answer:

Explanation

Privacy by Design (PbD) is a methodology for proactively embedding privacy into the design and operation of IT systems, business practices, and new programs from the very beginning. The question asks for a process to add privacy protections to a new program being developed. PbD is the most effective and appropriate process for this, as its core principle is to anticipate and prevent privacy-invasive events before they happen. This approach aligns perfectly with the organization's goal to mature its program and ensure privacy is an integral "part of the end product of any process of technological development," moving beyond a purely reactive, breach-prevention posture.

Why Incorrect

B. Privacy Step Assessment: This is not a recognized or standard term within established privacy management frameworks; it is a distractor.

C. Information Security Planning: This is a critical but narrower component of a privacy program. It focuses on security controls, not the full spectrum of privacy principles like purpose limitation or data minimization.

D. Innovation Privacy Standards: This is not a standard industry term for a process. Standards are the requirements or rules, whereas PbD is the proactive methodology for implementing them during development.

References

1. Densmore

R. (2019). Privacy Program Management: Tools for Managing Privacy Within Your Organization (3rd ed.). IAPP. In Chapter 5

"The Privacy Operational Life Cycle

" the text explains that Privacy by Design is the process of embedding privacy controls into the "Design" phase of any new product or service (pp. 151-153).

2. Cavoukian

A. (2009). Privacy by Design: The 7 Foundational Principles. Information and Privacy Commissioner of Ontario

Canada. The first principle

"Proactive not Reactive; Preventative not Remedial

" directly addresses the scenario's need to build privacy into a new program from the start rather than correcting issues after the fact (p. 2).

3. National Institute of Standards and Technology. (2017). NISTIR 8062: An Introduction to Privacy Engineering and Risk Management in Federal Systems. Section 2.2

"Relationship to the System Development Life Cycle

" emphasizes that "privacy is a cross-cutting concern that needs to be addressed at all stages of the SDLC

" which is the operational application of Privacy by Design principles (p. 7).

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