CDPSE Exam Results

A retention schedule is a document that specifies how long different types of records or data should be kept and when they should be deleted or disposed of, based on legal, regulatory, operational or historical requirements. A retention schedule is the best indication of an effective records management program for personal data, as it reflects the principles of data minimization and storage limitation, which require limiting the collection, storage and processing of personal data to what is necessary and relevant for the intended purposes, and deleting or disposing of personal data when it is no longer needed or justified. A retention schedule also helps to reduce the privacy risks and costs associated with data storage and retention, such as data breaches, unauthorized access, misuse or loss of data. The other options are not as indicative of an effective records management program for personal data as a retention schedule. Archived data is used for future analytics may indicate that the organization is leveraging its data assets for business intelligence or research purposes, but it may not comply with the principles of data minimization and storage limitation, or the privacy rights and preferences of the data subjects. The legal department has approved the retention policy may indicate that the organization has obtained legal advice or guidance on its records management program for personal data, but it may not reflect the actual implementation or execution of the retention policy. All sensitive data has been tagged may indicate that the organization has implemented a data classification scheme for its records or data, but it may not indicate how long the records or data should be kept or when they should be deleted or disposed of1, p. 99-100 References: 1: CDPSE Review Manual (Digital Version)

The best control to prevent data leakage for a cloud-based HR solution with a mobile application interface is to disable the download of data to the mobile devices. This is because downloading data to the mobile devices increases the risk of data loss, theft, or unauthorized access, especially if the devices are lost, stolen, or compromised. Disabling the download of data to the mobile devices ensures that the data remains in the cloud-based solution, where it can be protected by encryption, access control, and other security measures. The other options are not as effective or sufficient as disabling the download of data to the mobile devices, as they do not address the root cause of the data leakage risk, which is the exposure of data outside the cloud-based solution.

References: CDPSE Review Manual, 2021, p. 128

Code review is a primary element of application and software hardening. Code review is a process of examining the source code of an application or software to identify and fix errors, vulnerabilities, or inefficiencies that may compromise its functionality, security, or performance. Code review can help prevent common security risks such as buffer overflows, SQL injections, cross-site scripting, or logic flaws. Code review can also help improve the quality, readability, maintainability, and usability of the code. Code review can be done manually by developers or peers, or automatically by tools such as static code analyzers or code quality checkers.

Vulnerability analysis, database configuration, and software repository are also important for application and software hardening, but they are not primary elements. Vulnerability analysis is a process of identifying and assessing the weaknesses or flaws in an application or software that may expose it to attacks or exploitation. Vulnerability analysis can be done by tools such as vulnerability scanners or penetration testers. Database configuration is a process of setting up and managing the parameters, options, or features of a database system that stores or processes data for an application or software. Database configuration can include aspects such as access control, encryption, backup, recovery, performance tuning, or replication. Software repository is a location where the source code, binaries, or documentation of an application or software are stored and managed. Software repository can facilitate version control, collaboration, distribution, or deployment of the application or software.

References: What is Application Hardening ? - GeeksforGeeks, What is OS Hardening and How Can Developers Implement it, System Hardening: An Easy-to-Understand Overview - Trenton Systems

The best way to validate compliance with agreed-upon service levels established with a third party that processes personal data is to have a contractual right to audit, which means that the organization can conduct audits or inspections of the third party’s privacy practices, policies, and procedures to verify that they meet the contractual obligations and expectations. A contractual right to audit can also help identify and address any privacy risks or gaps that may arise from the third party’s processing of personal data12.

References:

• CDPSE Exam Content Outline, Domain 1 – Privacy Governance (Governance, Management & Risk Management), Task 7: Participate in the management and evaluation of contracts, service levels and practices of vendors and other external parties3.
• CDPSE Review Manual, Chapter 1 – Privacy Governance, Section 1.4 – Third-Party Management4.