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The GLBA prohibits financial institutions from disclosing a consumer’s account number or similar form of access number or access code to any nonaffiliated third party for use in telemarketing, direct mail marketing, or other marketing through electronic mail to the consumer. This restriction is intended to prevent unauthorized access to a person’s bank account by third parties who may use the account number to initiate fraudulent transactions or identity theft. The GLBA also requires financial institutions to implement safeguards to protect the security, confidentiality, and integrity of customer information, and to notify customers and regulators in the event of a security breach involving such information. References:

IAPP CIPP/US Certified Information Privacy Professional Study Guide, Chapter 2: Limits on Private-sector Collection and Use of Data, Section 2.3: Financial Privacy, p. 49-50

IAPP CIPP/US Body of Knowledge, Domain II: Limits on Private-sector Collection and Use of Data, Objective II.C: Identify the privacy requirements for financial institutions, Subobjective II.C.2: Identify the restrictions on disclosure of account numbers, p. 14

IAPP CIPP/US Exam Blueprint, Domain II: Limits on Private-sector Collection and Use of Data, Objective II.C: Identify the privacy requirements for financialinstitutions, Subobjective II.C.2: Identify the restrictions on disclosure of account numbers, p. 5

The Civil Rights Act, Pregnancy Discrimination Act, Americans with Disabilities Act, Age Discrimination Act, and Equal Pay Act are all federal laws that prohibit employment discrimination based on certain protected characteristics, such as race, sex, disability, age, and pay1234 These laws also afford certain classes of employees’ privacy protection by limiting inquiries concerning their personal information that may reveal their protected status or be used for discriminatory purposes. For example:

The Civil Rights Act of 1964 prohibits employers from making pre-employment inquiries that express a preference, limitation, or specification based on race, color, religion, sex, or national origin, unless they are bona fide occupational qualifications.

The Pregnancy Discrimination Act of 1978, which amended the Civil Rights Act of 1964, prohibits employers from making pre-employment inquiries about whether an applicant is pregnant or intends to become pregnant, unless they are related to the ability to perform the job.

The Americans with Disabilities Act of 1990 prohibits employers from making pre-employment inquiries about whether an applicant has a disability or the nature or severity of a disability, unless they are related to the ability to perform the essential functions of the job with or without reasonable accommodation.

The Age Discrimination in Employment Act of 1967 prohibits employers from making pre-employment inquiries about an applicant’s age, unless they are related to a bona fide occupational qualification or a lawful affirmative action plan.

The Equal Pay Act of 1963 prohibits employers from making pre-employment inquiries about an applicant’s salary history, unless they are made for a lawful purpose other than determining the applicant’s pay.

Option A is incorrect because these laws do not require employers not to discriminate against certain classes when employees use personal information. Rather, they require employers not to discriminate against certain classes in any aspect of employment, such as hiring, firing, pay, promotion, training, benefits, etc1234 The use of personal information by employees is not directly addressed by these laws, although it may be subject to other privacy laws or policies.

Option B is incorrect because these laws do not require that employers provide reasonable accommodations to certain classes of employees. Rather, only the Americans with Disabilities Act and the Pregnancy Discrimination Act require employers to provide reasonable accommodations to qualified individuals with disabilities and workers with limitations related to pregnancy, childbirth, or related medical conditions, respectively, unless doing so would cause an undue hardship to the employer. The other laws do not have a similar requirement, although they may prohibit employers from denying equal opportunities to certain classes of employees.

Option C is correct because these laws afford certain classes of employees’ privacy protection by limiting inquiries concerning their personal informationthat may reveal their protected status or be used for discriminatory purposes, as explained above.

Option D is incorrect because these laws do not permit employers to use or disclose personal information specifically about employees who are members of certain classes. Rather, these laws generally prohibit employers from using or disclosing personal information that is protected by these laws for any unlawful or discriminatory purpose, unless an exception applies. For example, employers may use or disclose such information for legitimate business reasons, such as complying with reporting requirements, administering benefits, or conducting investigations.

References: 1: Facts About Equal Pay and Compensation Discrimination 2: Pregnancy Discrimination and Pregnancy-Related Disability Discrimination | U.S. Equal Employment Opportunity Commission 3: Regulations, Guidance and Policy | Equal Opportunity Guidance | OEEOWE 4: Age Discrimination | U.S. Equal Employment Opportunity Commission : Pre-Employment Inquiries and Medical Questions & Examinations | U.S. Equal Employment Opportunity Commission : Employee Medical Information | U.S. Equal Employment Opportunity Commission : Employee Privacy Rights | U.S. Department of Labor : Title VII of the Civil Rights Act of 1964 | U.S. Equal Employment Opportunity Commission : Fact Sheet: Pregnancy Discrimination | U.S. Equal Employment Opportunity Commission : The Americans with Disabilities Act: A Primer for Small Business : Age Discrimination in Employment Act of 1967 | U.S. Equal Employment Opportunity Commission : Equal Pay Act of 1963 | U.S. Equal Employment Opportunity Commission

 Matt’s decision to report the marketer’s activities is based on his suspicion that the marketer violated the Children’s Online Privacy Protection Act (COPPA), which is a federal law that regulates the online collection, use, and disclosure of personal information from children under 13 years of age1. According to COPPA, operators of websites or online services that are directed to children or knowingly collect personal information from children must:

Provide notice to parents about their information practices and obtain verifiable parental consent before collecting, using, or disclosing personal information from children12.

Give parents the choice of consenting to the operator’s collection and internal use of a child’s information, but prohibiting the operator from disclosing that information to third parties (unless disclosure is integral to the site or service, in which case, this must be made clear to parents)12.

Provide parents access to their child’s personal information to review and/or have the information deleted and give parents the opportunity to prevent further use or online collection of a child’s personal information12.

Maintain the confidentiality, security, and integrity of information they collect from children, including by taking reasonable steps to release such information only to parties capable of maintaining its confidentiality and security12.

Retain personal information collected online from a child for only as long as is necessary to fulfill the purpose for which it was collected and delete the information using reasonable measures to protect against its unauthorized access or use12.

Establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of personal information collected from children12.

In Matt’s case, he did not receive any notice from the marketer about the survey or the contest, nor did he give his consent for the collection or disclosure of his son’s personal information. He also did not have any access or control over his son’s information or the ability to prevent further use or collection. Moreover, he noticed that his son’s information seemed to have been shared with other marketers, as evidenced by the commercial emails in his son’s inbox. These actions indicate that the marketer did not comply with COPPA’s requirements and may have exposed his son’s information to unauthorized or inappropriate parties. Therefore, Matt decided to report the marketer’s activities to the proper authorities, such as the Federal Trade Commission (FTC), which enforces COPPA and can impose civil penalties for violations13. References: 1: Children’s Online Privacy Protection Act | Federal Trade Commission, 1. 2: 16 CFR Part 312 – Children’s Online Privacy Protection Rule, 3. 3: Children’s Online Privacy Protection Act - Wikipedia, 2.

The APEC Privacy Framework is a set of non-binding principles adopted by the Asia-Pacific Economic Cooperation (APEC) that aim to promote electronic commerce and protect information privacy in the region. The Framework is consistent with the core values of the OECD Guidelines on the Protection of Privacy and Trans-Border Flows of Personal Data, and reaffirms the value of privacy to individuals and to the information society. The Framework consists of nine principles: Preventing Harm, Notice, Collection Limitation, Use of Personal Information, Choice, Integrity of Personal Information, Security Safeguards, Access and Correction, and Accountability. Privacy by Design is not one of the principles in the APEC Privacy Framework, although it is a concept that is endorsed by the OECD Guidelines and other privacyframeworks. References: APEC Privacy Framework (2015), APEC Privacy Principles, IAPP CIPP/US Study Guide, Chapter 4.