CDPSE Exam Dumps - Isaca Certification Questions and Answers

Ensuring appropriate data classification should be done next after a migration of personal data involving a data source with outdated documentation has been approved by senior management, as it helps to identify the types, locations, and owners of the data, and to apply the appropriate privacy controls and measures based on the data classification level. Data classification also facilitates the data discovery, data minimization, data retention, and data disposal processes15. References: 1 Domain 3, Task 2; 5 Page 9

Performing a full wipe and reimage of the laptops is the best control to prevent the exposure of personal information when redeploying laptops within an organization. This is because a full wipe and reimage ensures that all data, including personal information, is securely erased from the laptops and replaced with a fresh installation of the operating system and applications. This reduces the risk of data leakage, unauthorized access, or data recovery by malicious actors or unauthorized users. The other options are not as effective or sufficient as a full wipe and reimage, as they do not guarantee the complete removal of personal information from the laptops.

References: CDPSE Review Manual, 2021, p. 147

A data processor that handles personal data for multiple customers has decided to migrate its data warehouse to a third-party provider. The processor is obligated to seek approval from all in-scope data controllers prior to implementation. A data controller is an entity that determines the purposes and means of processing personal data. A data processor is an entity that processes personal data on behalf of a data controller. A third-party provider is an entity that provides services or resources to another entity, such as a cloud service provider or a hosting provider.

According to various privacy laws and regulations, such as the GDPR or the CCPA, a data processor must obtain explicit consent from the data controller before engaging another processor or transferring personal data to a third country or an international organization. The consent must specify the identity of the other processor or the third country or international organization, as well as the safeguards and guarantees for the protection of personal data. The consent must also be documented in a written contract or other legal act that binds the processor to respect the same obligations as the controller.

Seeking approval from all in-scope data controllers can help ensure that the processor complies with its contractual and legal obligations, respects the rights and preferences of the data subjects, and maintains transparency and accountability for its processing activities.

Obtaining assurance that data subject requests will continue to be handled appropriately, implementing comparable industry-standard data encryption in the new data warehouse, or ensuring data retention periods are documented are also good practices for a data processor that migrates its data warehouse to a third-party provider, but they are not obligations prior to implementation. Rather, they are requirements or recommendations during or after implementation.

Obtaining assurance that data subject requests will continue to be handled appropriately is a requirement for a data processor that processes personal data on behalf of a data controller. Data subject requests are requests made by individuals to exercise their rights regarding their personal data, such as access, rectification, erasure, restriction, portability, or objection. A data processor must assist the data controller in fulfilling these requests within a reasonable time frame and without undue delay.

Implementing comparable industry-standard data encryption in the new data warehouse is a recommendation for a data processor that transfers personal data to another system or location. Data encryption is a process of transforming data into an unreadable form using a secret key or algorithm. Data encryption can help protect the confidentiality, integrity, and availability of personal data by preventing unauthorized access, disclosure, or modification.

Ensuring data retention periods are documented is a requirement for a data processor that stores personal data on behalf of a data controller. Data retention periods are the durations for which personal data are kept before they are deleted or anonymized. Data retention periods must be determined by the purpose and necessity of processing personal data and must comply with legal and regulatory obligations.

References: Data warehouse migration tips: preparation and discovery - Google Cloud, Plan a data warehouse migration - Cloud Adoption Framework, Migrating your traditional data warehouse platform to BigQuery …

When contracting with a SaaS provider, it is important to ensure that the provider will remove all customer data from their systems and storage devices at the end of the service contract. This will prevent any unauthorized access, use, or disclosure of the customer data by the provider or third parties after the service termination. Removal of customer data means that the data are permanently erased and cannot be recovered or restored by any means.

References:

• ISACA, Data Privacy Audit/Assurance Program, Control Objective 9: Data Disposal, p. 16-171
• ISACA, CDPSE Review Manual 2021, Chapter 4: Privacy Incident Response, Section 4.2: Data Disposal and Destruction, p. 151-152.

Data privacy and data security are related but distinct concepts that are both essential for protecting personal data. Data privacy is about ensuring that personal data are collected, used, shared and disposed of in a lawful, fair and transparent manner, respecting the rights and preferences of the data subjects. Data privacy also involves implementing policies, procedures and controls to comply with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA). Data privacy protects users from unauthorized disclosure of their personal data, which may result in harm, such as identity theft, fraud, discrimination or reputational damage.

Data security is about safeguarding the confidentiality, integrity and availability of data from unauthorized or malicious access, use, modification or destruction. Data security also involves implementing technical and organizational measures to prevent or mitigate data breaches or incidents, such as encryption, authentication, backup or incident response. Data security prevents compromise of data, which may result in loss, corruption or disruption of data.

References:

• The Difference Between Data Privacy and Data Security - ISACA, section 1: “Data privacy is focused on the use and governance of personal data—things like putting policies in place to ensure that consumers’ personal information is being collected, shared and used in appropriate ways.”
• Practical Data Security and Privacy for GDPR and CCPA - ISACA, section 1: “Data security is the practice of protecting digital information from unauthorized access, corruption or theft throughout its life cycle.”

 Including privacy requirements in vendor contracts is the best way to ensure privacy considerations are included when working with vendors because it establishes the obligations, expectations and responsibilities of both parties regarding the protection of personal data. It also provides a legal basis for enforcing compliance and resolving disputes. Including privacy requirements in the request for proposal (RFP) process, monitoring privacy-related service level agreements (SLAs) and requiring vendors to complete privacy awareness training are helpful measures, but they do not guarantee that vendors will adhere to the privacy requirements or that they will be held accountable for any violations.

References:

• CDPSE Review Manual (Digital Version), Domain 1: Privacy Governance, Task 1.7: Participate in the management and evaluation of contracts, service levels and practices of vendors and other external parties1
• CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 2: Privacy Governance, Section: Vendor Management2

A mobile application implementation should meet the organization’s data security standards by ensuring that the application does not contain any vulnerabilities, errors or malicious code that could compromise the confidentiality, integrity or availability of the data. An automatic dynamic code scan is a technique that analyzes the application code while it is running to detect and report any security issues or defects. An automatic dynamic code scan can help to identify and fix any potential data security risks before the application is deployed. The other options are not sufficient to ensure data security standards. UAT is a process of verifying that the application meets the user requirements and expectations, but it does not necessarily test for data security. Data classification is a process of categorizing data according to its sensitivity and value, but it does not ensure that the data is protected by the application. A PIA is a process of identifying and evaluating the privacy impacts of a system or project that involves personal data, but it does not ensure that the system or project meets data security standards. , p. 89-90 References: : CDPSE Review Manual (Digital Version)

The value proposition of a PIA is not understood by management is the greatest obstacle to conducting a PIA, as it may result in lack of support, funding, resources or commitment for the PIA process and outcomes. Management may not appreciate or recognize the benefits of a PIA, such as enhancing privacy protection, reducing privacy risks and costs, increasing customer trust and satisfaction, and complying with privacy laws and regulations. Management may also perceive a PIA as a burden, a delay or a hindrance to the system or project development and delivery. The other options are not as significant as the value proposition of a PIA is not understood by management as obstacles to conducting a PIA. Conducting a PIA requires significant funding and resources is an obstacle to conducting a PIA, but it may be overcome by demonstrating the return on investment or the cost-benefit analysis of a PIA. PIAs need to be performed many times in a year is an obstacle to conducting a PIA, but it may be mitigated by adopting a scalable or modular approach to PIAs that can be tailored to different types or levels of systems or projects. The organization lacks knowledge of PIA methodology is an obstacle to conducting a PIA, but it may be resolved by acquiring or developing the necessary skills, tools or guidance for performing PIAs1, p. 67-68 References: 1: CDPSE Review Manual (Digital Version)

Anonymization is a technique that removes or modifies personal data in such a way that it can no longer be attributed to a specific data subject. Anonymization can be achieved by various methods, such as encryption, pseudonymization, aggregation, generalization, etc. When using anonymization techniques to prevent unauthorized access to personal data, the most important consideration to ensure the data is adequately protected is that the key must be kept separate and distinct from the data it protects. The key is a piece of information that is used to reverse the anonymization process and restore the original personal data. The key must be stored and managed in a secure location that is different from where the anonymized data is stored and processed. This way, even if the anonymized data is compromised, the key cannot be accessed or used to re-identify the data subjects. References: : CDPSE Review Manual (Digital Version), page 29