CDPSE Exam Dumps - Isaca Certification Questions and Answers

A data loss prevention (DLP) tool is a software solution that monitors, detects and prevents the unauthorized transmission or leakage of sensitive data, such as personal data, from an organization’s network or devices. A DLP tool can help to ensure the effectiveness of a policy requiring the encryption of personal data if transmitted through email, by applying the following controls:

• Scanning the content and attachments of outgoing emails for personal data, such as names, email addresses, biometric data, IP addresses, etc.
• Blocking or quarantining emails that contain unencrypted personal data, and alerting the sender and/or the administrator of the policy violation.
• Encrypting personal data automatically before sending them through email, using encryption standards and algorithms that are compliant with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA).
• Generating audit logs and reports of email activities and incidents involving personal data, and providing visibility and accountability for policy compliance.

The other options are less effective or irrelevant to ensure the effectiveness of the policy. Providing periodic user awareness training on data encryption is a good practice, but it does not guarantee that users will follow the policy or know how to encrypt personal data properly. Conducting regular control self-assessments (CSAs) is a useful method to evaluate the design and operation of the policy, but it does not prevent or detect policy violations in real time. Enforcing annual attestation to policy compliance is a formal way to demonstrate user commitment to the policy, but it does not verify or measure the actual level of compliance.

References:

• The Complexity Conundrum: Simplifying Data Security - ISACA, section 3: “Data loss prevention (DLP) solutions can help prevent unauthorized access to sensitive information by monitoring network traffic for specific keywords or patterns.”
• Guide to Securing Personal Data in Electronic Medium, section 3.2: “Organisations should consider implementing DLP solutions to prevent unauthorised disclosure of personal data via email.”
• Encryption in the Hands of End Users - ISACA, section 2: “A key goal of encryption is to protect the file even when direct access is possible or the transfer is intercepted.”

A PIA is a systematic process to identify and evaluate the potential privacy impacts of a system, project, program or initiative that involves the collection, use, disclosure or retention of personal data. A PIA should be conducted as early as possible in the system lifecycle, preferably during the development stage, to ensure that privacy risks are identified and mitigated before the system is deployed. Conducting a PIA during functional testing, UAT or production stages may be too late to address privacy issues effectively and may result in costly rework or delays1, p. 67 References: 1: CDPSE Review Manual (Digital Version)

The first thing to do when a data collection process is deemed to be a high-level risk is to conduct a privacy impact assessment (PIA). A PIA is a systematic process that identifies and evaluates the potential effects of personal data processing operations on the privacy of individuals and the organization. A PIA helps to identify privacy risks and mitigation strategies at an early stage of the data collection process and ensures compliance with legal and regulatory requirements. A PIA also helps to demonstrate accountability and transparency to stakeholders and data subjects regarding how their personal data are collected, used, shared, stored, or deleted.

Performing a business impact analysis (BIA), implementing remediation actions to mitigate privacy risk, or creating a system of records notice (SORN) are also important steps for managing privacy risk, but they are not the first thing to do. Performing a BIA is a process of analyzing the potential impacts of disruptive events on the organization’s critical functions, processes, resources, or objectives. A BIA helps to determine the recovery priorities, strategies, and objectives for the organization in case of a disaster or crisis. Implementing remediation actions is a process of applying corrective or preventive measures to reduce or eliminate the privacy risks identified by the PIA or other methods. Remediation actions may include technical, organizational, or legal solutions, such as encryption, access control, consent management, or contractual clauses. Creating a SORN is a process of publishing a public notice that describes the existence and purpose of a system of records that contains personal data under the control of a federal agency. A SORN helps to inform the public about how their personal data are collected and maintained by the agency and what rights they have regarding their data.

References: Privacy Impact Assessment (PIA) - European Commission, Privacy Impact Assessment (PIA) | ICO, Privacy Impact Assessments | HHS.gov

The organization’s potential legal liabilities related to the data should be of greatest concern when an organization wants to store personal data in the cloud, as it may expose the organization to various compliance risks, such as data breach notification laws, data protection regulations, data sovereignty laws, and contractual obligations. The organization should ensure that the cloud storage provider complies with the applicable legal and regulatory requirements, and that the organization retains control and ownership of the data. The organization should also conduct due diligence and risk assessment of the cloud storage provider before entering into a contract. References: 2 Domain 2, Task 9; 4 

Encryption is a security practice that transforms data into an unreadable format using a secret key or algorithm. Encryption protects the confidentiality and integrity of data, especially when they are transferred using email or other communication channels. Encryption ensures that only authorized parties can access and use the data, while unauthorized parties cannot decipher or modify the data without the key or algorithm. Encryption also helps to comply with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which require data controllers and processors to implement appropriate technical and organizational measures to safeguard personal data.

Centrally managed encryption is a type of encryption that is implemented and controlled by a central authority or system, such as an organization or a service provider. Centrally managed encryption has the following advantages over end user-managed encryption, private cloud storage space, or password-protected .zip files, for reducing the risk of compromise when transferring personal information using email:

• It can enforce consistent and standardized encryption policies and procedures across the organization or the service, such as the encryption standards, algorithms, keys, modes, and formats.
• It can automate the encryption and decryption processes for the users, without requiring them to perform any manual actions or install any software or plug-ins on their devices.
• It can monitor and audit the encryption activities and incidents, and provide visibility and accountability for the data protection and compliance status.
• It can reduce the human errors or negligence that may compromise the encryption security, such as losing or sharing the keys, forgetting or reusing the passwords, or sending the data to the wrong recipients.

References:

• Encryption in the Hands of End Users - ISACA, section 2: “A key goal of encryption is to protect the file even when direct access is possible or the transfer is intercepted.”
• The Complexity Conundrum: Simplifying Data Security - ISACA, section 3: “Centrally managed encryption solutions can help enterprises overcome these challenges by providing a unified platform for encrypting data across different environments and applications.”
• Email Encryption: What You Need to Know - Lifewire, section 1: “Email encryption is a way of protecting your email messages from being read by anyone other than the intended recipients.”

The organization should disclose the relationship to those affected in jurisdictions where such disclosures are required, as this is the most appropriate and compliant action to take after identifying a privacy risk related to third-party data collection. Disclosing the relationship to the data subjects is a way of providing transparency and accountability, as well as respecting their rights and choices regarding their personal data. It also helps the organization avoid regulatory fines or sanctions for not complying with the applicable privacy laws or regulations that mandate such disclosures. The other options are not as effective or sufficient as disclosing the relationship, as they do not address the root cause of the risk, do not mitigate the potential harm to the data subjects, or do not align with the privacy principles and best practices.

References: CDPSE Review Manual, 2021, p. 36

A thin client remote desktop protocol (RDP) is the most effective remote access model for reducing the likelihood of attacks originating from connecting devices, because it minimizes the amount of data and processing that occurs on the remote device. A thin client RDP only sends keyboard, mouse and display information between the remote device and the server, while the actual processing and storage of data happens on the server. This reduces the exposure of sensitive data and applications to potential attackers who may compromise the remote device.

References:

• CDPSE Review Manual, Chapter 2 – Privacy Architecture, Section 2.3 – Privacy Architecture Implementation1.
• CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 2 – Privacy Architecture, Section 2.4 – Remote Access2.

The best approach for a local office of a global organization faced with multiple privacy-related compliance requirements is to focus on the requirements with the highest organizational impact, because this will help prioritize the most critical and urgent privacy issues and risks that may affect the organization’s reputation, operations, or legal obligations. Focusing on the highest impact requirements will also help allocate the resources and efforts more efficiently and effectively, as well as align the local office’s privacy practices with the global organization’s objectives and strategies12.

References:

• CDPSE Exam Content Outline, Domain 1 – Privacy Governance (Governance, Management & Risk Management), Task 3: Participate in the evaluation of privacy policies, programs and policies for their alignment with legal requirements, regulatory requirements and/or industry best practices3.
• CDPSE Review Manual, Chapter 1 – Privacy Governance, Section 1.2 – Privacy Policy4.

From a privacy perspective, it is most important to ensure data backups are encrypted. Encryption is a process of transforming data into an unreadable form using a secret key or algorithm. Encryption can help protect the confidentiality, integrity, and availability of data backups by preventing unauthorized access, disclosure, or modification. Encryption can also help comply with legal and regulatory requirements for data protection, such as the General Data Protection Regulation (GDPR) or the Health Insurance Portability and Accountability Act (HIPAA). Encryption can be applied to data backups at different levels, such as file-level, disk-level, or network-level encryption.

Incremental backups, differential backups, or pseudonymization are also useful for data backup management, but they are not the most important from a privacy perspective. Incremental backups are backups that only copy the data that has changed since the last backup, whether it was a full, differential, or incremental backup. Incremental backups can help save storage space and time, but they do not directly protect the data from unauthorized access or disclosure. Differential backups are backups that only copy the data that has changed since the last full backup. Differential backups can also help save storage space and time, but they also do not directly protect the data from unauthorized access or disclosure. Pseudonymization is a process of replacing identifying information in data with artificial identifiers or pseudonyms. Pseudonymization can help enhance the privacy of data by reducing the linkability between data and data subjects, but it does not prevent re-identification or inference attacks.

References: Data backups 101: A complete guide for 2023 - Norton, Backup & Secure | U.S. Geological Survey - USGS.gov, The GDPR: How the right to be forgotten affects backups

After a privacy risk has been accepted, the next step is to monitor the risk landscape for material changes. This means that the organization should keep track of any internal or external factors that may affect the likelihood or impact of the risk, such as new threats, vulnerabilities, regulations, technologies, or business processes. Monitoring the risk landscape can help the organization identify if the risk acceptance decision is still valid, or if it needs to be revisited or revised. Monitoring can also help the organization prepare for potential incidents or consequences that may arise from the accepted risk.