Certified Information Privacy Technologist CIPT Certification Study Guide

1. SCENARIO

Carol was a U.S.-based glassmaker who sold her work at art festivals. She kept things simple by only accepting cash and personal checks.

As business grew, Carol couldn't keep up with demand, and traveling to festivals became burdensome. Carol opened a small boutique and hired Sam to run it while she worked in the studio. Sam was a natural salesperson, and business doubled. Carol told Sam, “I don't know what you are doing, but keep doing it!"

But months later, the gift shop was in chaos. Carol realized that Sam needed help so she hired Jane, who had business expertise and could handle the back-office tasks. Sam would continue to focus on sales. Carol gave Jane a few weeks to get acquainted with the artisan craft business, and then scheduled a meeting for the three of them to discuss Jane's first impressions.

At the meeting, Carol could not wait to hear Jane's thoughts, but she was unprepared for what Jane had to say. “Carol, I know that he doesn't realize it, but some of Sam’s efforts to increase sales have put you in a vulnerable position. You are not protecting customers’ personal information like you should.”

Sam said, “I am protecting our information. I keep it in the safe with our bank deposit. It's only a list of customers’ names, addresses and phone numbers that I get from their checks before I deposit them. I contact them when you finish a piece that I think they would like.

That's the only information I have! The only other thing I do is post photos and information about your work on the photo sharing site that I use with family and friends. I provide my email address and people send me their information if they want to see more of your work. Posting online really helps sales, Carol. In fact, the only complaint I hear is about having to come into the shop to make a purchase.”

Carol replied, “Jane, that doesn’t sound so bad. Could you just fix things and help us to post even more online?"

‘I can," said Jane. “But it's not quite that simple. I need to set up a new program to make sure that we follow the best practices in data management. And I am concerned for our customers. They should be able to manage how we use their personal information. We also should develop a social media strategy.”

Sam and Jane worked hard during the following year. One of the decisions they made was to contract with an outside vendor to manage online sales. At the end of the year, Carol shared some exciting news. “Sam and Jane, you have done such a great job that one of the biggest names in the glass business wants to buy us out! And Jane, they want to talk to you about merging all of our customer and vendor information with theirs beforehand."

What type of principles would be the best guide for Jane's ideas regarding a new data management program?

2. SCENARIO

Clean-Q is a company that offers house-hold and office cleaning services. The company receives requests from consumers via their website and telephone, to book cleaning services. Based on the type and size of service, Clean-Q then contracts individuals that are registered on its resource database - currently managed in-house by Clean-Q IT Support. Because of Clean-Q's business model, resources are contracted as needed instead of permanently employed.

The table below indicates some of the personal information Clean-Q requires as part of its business operations:





Clean-Q has an internal employee base of about 30 people. A recent privacy compliance exercise has been conducted to align employee data management and human resource functions with applicable data protection regulation. Therefore, the Clean-Q permanent employee base is not included as part of this scenario.

With an increase in construction work and housing developments, Clean-Q has had an influx of requests for cleaning services. The demand has overwhelmed Clean-Q's traditional supply and demand system that has caused some overlapping bookings.

Ina business strategy session held by senior management recently, Clear-Q invited vendors to present potential solutions to their current operational issues. These vendors included Application developers and Cloud-Q’s solution providers, presenting their proposed solutions and platforms.

The Managing Director opted to initiate the process to integrate Clean-Q's operations with a cloud solution (LeadOps) that will provide the following solution one single online platform: A web interface that Clean-Q accesses for the purposes of resource and customer management. This would entail uploading resource and customer information.

✑ A customer facing web interface that enables customers to register, manage and submit cleaning service requests online.

✑ A resource facing web interface that enables resources to apply and manage their assigned jobs.

✑ An online payment facility for customers to pay for services.

If Clean-Q were to utilize LeadOps' services, what is a contract clause that may be included in the agreement entered into with LeadOps?

3. What is an Access Control List?

4. What is the main reason the Do Not Track (DNT) header is not acknowledged by more companies?

5. SCENARIO

Kyle is a new security compliance manager who will be responsible for coordinating and

executing controls to ensure compliance with the company's information security policy and industry standards. Kyle is also new to the company, where collaboration is a core value. On his first day of new-hire orientation, Kyle's schedule included participating in meetings and observing work in the IT and compliance departments.

Kyle spent the morning in the IT department, where the CIO welcomed him and explained that her department was responsible for IT governance. The CIO and Kyle engaged in a conversation about the importance of identifying meaningful IT governance metrics. Following their conversation, the CIO introduced Kyle to Ted and Barney. Ted is implementing a plan to encrypt data at the transportation level of the organization's wireless network. Kyle would need to get up to speed on the project and suggest ways to monitor effectiveness once the implementation was complete. Barney explained that his short-term goals are to establish rules governing where data can be placed and to minimize the use of offline data storage.

Kyle spent the afternoon with Jill, a compliance specialist, and learned that she was exploring an initiative for a compliance program to follow self-regulatory privacy principles. Thanks to a recent internship, Kyle had some experience in this area and knew where Jill could find some support. Jill also shared results of the company’s privacy risk assessment, noting that the secondary use of personal information was considered a high risk.

By the end of the day, Kyle was very excited about his new job and his new company. In fact, he learned about an open position for someone with strong qualifications and experience with access privileges, project standards board approval processes, and application-level obligations, and couldn’t wait to recommend his friend Ben who would be perfect for the job.

Which data practice is Barney most likely focused on improving?

6. Which of the following is an example of the privacy risks associated with the Internet of

Things (loT)?

7. Which is NOT a way to validate a person's identity?

8. A user who owns a resource wants to give other individuals access to the resource .

What control would apply?

9. What is true of providers of wireless technology?

10. What must be done to destroy data stored on "write once read many" (WORM) media?

11. Which of the following is an example of drone “swarming”?

12. Which of the following became a foundation for privacy principles and practices of countries and organizations across the globe?

13. What distinguishes a "smart" device?

14. Users of a web-based email service have their accounts breached through compromised login credentials .

Which possible consequences of the breach illustrate the two categories of Calo’s Harm Dimensions?

15. Implementation of privacy controls for compliance with the requirements of the Children’s Online Privacy Protection Act (COPPA) is necessary for all the following situations EXCEPT?

16. SCENARIO

Kyle is a new security compliance manager who will be responsible for coordinating and executing controls to ensure compliance with the company's information security policy and industry standards. Kyle is also new to the company, where collaboration is a core value. On his first day of new-hire orientation, Kyle's schedule included participating in meetings and observing work in the IT and compliance departments.

Kyle spent the morning in the IT department, where the CIO welcomed him and explained that her department was responsible for IT governance. The CIO and Kyle engaged in a conversation about the importance of identifying meaningful IT governance metrics. Following their conversation, the CIO introduced Kyle to Ted and Barney. Ted is implementing a plan to encrypt data at the transportation level of the organization's wireless network. Kyle would need to get up to speed on the project and suggest ways to monitor effectiveness once the implementation was complete. Barney explained that his short-term goals are to establish rules governing where data can be placed and to minimize the use of offline data storage.

Kyle spent the afternoon with Jill, a compliance specialist, and learned that she was exploring an initiative for a compliance program to follow self-regulatory privacy principles. Thanks to a recent internship, Kyle had some experience in this area and knew where Jill could find some support. Jill also shared results of the company’s privacy risk assessment, noting that the secondary use of personal information was considered a high risk.

By the end of the day, Kyle was very excited about his new job and his new company. In fact, he learned about an open position for someone with strong qualifications and experience with access privileges, project standards board approval processes, and application-level obligations, and couldn’t wait to recommend his friend Ben who would be perfect for the job.

Which of the following should Kyle recommend to Jill as the best source of support for her initiative?

17. 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 cryptographic standard would be most appropriate for protecting patient credit card information in the records system?

18. SCENARIO

You have just been hired by Ancillary.com, a seller of accessories for everything under the sun, including waterproof stickers for pool floats and decorative bands and cases for sunglasses. The company sells cell phone cases, e-cigarette cases, wine spouts, hanging air fresheners for homes and automobiles, book ends, kitchen implements, visors and shields for computer screens, passport holders, gardening tools and lawn ornaments, and catalogs full of health and beauty products. The list seems endless. As the CEO likes to say, Ancillary offers, without doubt, the widest assortment of low-price consumer products from a single company anywhere.

Ancillary's operations are similarly diverse. The company originated with a team of sales consultants selling home and beauty products at small parties in the homes of customers, and this base business is still thriving. However, the company now sells online through retail sites designated for industries and demographics, sites such as “My Cool Ride" for automobile-related products or “Zoomer” for gear aimed toward young adults. The company organization includes a plethora of divisions, units and outrigger operations, as Ancillary has been built along a decentered model rewarding individual initiative and flexibility, while also acquiring key assets. The retail sites seem to all function differently, and you wonder about their compliance with regulations and industry standards. Providing tech support to these sites is also a challenge, partly due to a variety of logins and authentication protocols.

You have been asked to lead three important new projects at Ancillary:

The first is the personal data management and security component of a multi-faceted initiative to unify the company’s culture. For this project, you are considering using a series of third- party servers to provide company data and approved applications to employees.

The second project involves providing point of sales technology for the home sales force, allowing them to move beyond paper checks and manual credit card imprinting.

Finally, you are charged with developing privacy protections for a single web store housing all the company’s product lines as well as products from affiliates. This new omnibus site will be known, aptly, as “Under the Sun.” The Director of Marketing wants the site not only to sell Ancillary’s products, but to link to additional products from other retailers through paid advertisements. You need to brief the executive team of security concerns posed by this approach.

If you are asked to advise on privacy concerns regarding paid advertisements, which is the most important aspect to cover?

19. SCENARIO

Please use the following to answer the next question:

Looking back at your first two years as the Director of Personal Information Protection and Compliance for the St. Anne’s 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 recall a recent visit to the Records Storage Section in the basement of the old hospital next to the modern facility, where you noticed paper records sitting in crates labeled by years, medical condition or alphabetically by patient name, while others were in undifferentiated bundles on shelves and on the floor. On the back shelves of the section sat data tapes and old hard drives that were often unlabeled but appeared to be years old. On your way out of the records storage section, you noticed a man leaving whom you did not recognize. He carried a batch of folders under his arm, apparently records he had removed from storage.

You quickly realize that you need a plan of action on the maintenance, secure storage and disposal of data.

Which cryptographic standard would be most appropriate for protecting patient credit card information in the records system at St. Anne’s Regional Medical Center?

20. After downloading and loading a mobile app, the user is presented with an account registration page requesting the user to provide certain personal details. Two statements are also displayed on the same page along with a box for the user to check to indicate their confirmation:

Statement 1 reads: “Please check this box to confirm you have read and accept the terms and conditions of the end user license agreement” and includes a hyperlink to the terms and conditions.

Statement 2 reads: “Please check this box to confirm you have read and understood the privacy notice” and includes a hyperlink to the privacy notice.

Under the General Data Protection Regulation (GDPR), what lawful basis would you primarily except the privacy notice to refer to?

21. Which of the following would best improve an organization’ s system of limiting data use?

22. In the realm of artificial intelligence, how has deep learning enabled greater implementation of machine learning?

23. Which of the following statements is true regarding software notifications and agreements?

24. 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.

What type of wireless network does GFDC seem to employ?

25. Which of the following would be the best method of ensuring that Information Technology projects follow Privacy by Design (PbD) principles?

26. Which of the following would be the most appropriate solution for preventing privacy violations related to information exposure through an error message?

27. Between November 30th and December 2nd, 2013, cybercriminals successfully infected the credit card payment systems and bypassed security controls of a United States-based retailer with malware that exfiltrated 40 million credit card numbers. Six months prior, the retailer had malware detection software installed to prevent against such an attack.

Which of the following would best explain why the retailer’s consumer data was still exfiltrated?

28. Which of the following provides a mechanism that allows an end-user to use a single sign-on (SSO) for multiple services?

29. SCENARIO

Please use the following to answer the next question:

Jordan just joined a fitness-tracker start-up based in California, USA, as its first Information Privacy and Security Officer. The company is quickly growing its business but does not sell any of the fitness trackers itself. Instead, it relies on a distribution network of third-party retailers in all major countries. Despite not having any stores, the company has a 78% market share in the EU. It has a website presenting the company and products, and a member section where customers can access their information. Only the email address and physical address need to be provided as part of the registration process in order to customize the site to the user’s region and country. There is also a newsletter sent every month to all members featuring fitness tips, nutrition advice, product spotlights from partner companies based on user behavior and preferences.

Jordan says the General Data Protection Regulation (GDPR) does not apply to the company. He says the company is not established in the EU, nor does it have a processor in the region. Furthermore, it does not do any “offering goods or services” in the EU since it does not do any marketing there, nor sell to consumers directly. Jordan argues that it is the customers who chose to buy the products on their own initiative and there is no “offering” from the company.

The fitness trackers incorporate advanced features such as sleep tracking, GPS tracking, heart rate monitoring. wireless syncing, calorie-counting and step-tracking. The watch must be paired with either a smartphone or a computer in order to collect data on sleep levels, heart rates, etc. All information from the device must be sent to the company’s servers in order to be processed, and then the results are sent to the smartphone or computer. Jordan argues that there is no personal information involved since the company does not collect banking or social security information.

Based on the current features of the fitness watch, what would you recommend be implemented into each device in order to most effectively ensure privacy?

30. What is a main benefit of data aggregation?