Rationalizing requirements in order to comply with the various privacy requirements required by applicable law and regulation does NOT include which of the following?

(As the data protection officer for the growing company. Vision 4634. what would be the most cost-effective way to monitor changes in laws and regulations?)

SCENARIO

Please use the following to answer the next QUESTION:

Paul Daniels, with years of experience as a CEO, is worried about his son Carlton's successful venture, Gadgo. A technological innovator in the communication industry that quickly became profitable, Gadgo has moved beyond its startup phase. While it has retained its vibrant energy, Paul fears that under Carlton's

direction, the company may not be taking its risks or obligations as seriously as it needs to. Paul has hired you, a Privacy Consultant, to assess the company and report to both father and son. "Carlton won't listen to me," Paul says, "but he may pay attention to an expert."

Gadgo's workplace is a clubhouse for innovation, with games, toys, snacks. espresso machines, giant fish tanks and even an iguana who regards you with little interest. Carlton, too, seems bored as he describes to you the company's procedures and technologies for data protection. It's a loose assemblage of controls, lacking consistency and with plenty of weaknesses. "This is a technology company," Carlton says. "We create. We innovate. I don't want unnecessary measures that will only slow people down and clutter their thoughts."

The meeting lasts until early evening. Upon leaving, you walk through the office it looks as if a strong windstorm has recently blown through, with papers scattered across desks and tables and even the floor. A "cleaning crew" of one teenager is emptying the trash bins. A few computers have been left on for the night, others are missing. Carlton takes note of your attention to this: "Most of my people take their laptops home with them, or use their own tablets or phones. I want them to use whatever helps them to think and be ready day or night for that great insight. It may only come once!"

What phase in the Privacy Maturity Model (PMM) does Gadgo's privacy program best exhibit?

Which of the following best describes proper compliance for an international organization using Binding Corporate Rules (BCRs) as a controller or processor?

What steps can an organization take to ensure its data inventory is kept up to date?

SCENARIO

Please use the following to answer the next QUESTION:

As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development.

You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.

Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both

the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place.

Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.

You are left contemplating:

What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success?

What are the next action steps?

What practice would afford the Director the most rigorous way to check on the program's compliance with laws, regulations and industry best practices?

When devising effective employee policies to address a particular issue, which of the following should be included in the first draft?

You are the privacy operations lead at a mid-size multi-national business to business (B2B) technology organization. The privacy program is moderately mature and you are looking to enhance and expand training and awareness at all levels of the business. You want to launch an effort that helps bring privacy into focus for specific job families, categories and lines of the business (e.g., developers, program managers, architects) but your privacy team is small and you don't have a large budget to make this happen.

You set up a meeting with internal communications to identify possible awareness opportunities to meet these objectives and have secured spots at several upcoming all team meetings to present on privacy. Your goals are to establish an enterprise-wide privacy program awareness plan and toolkit involving various stakeholders that is then tailored to internal operational departments.

(Which of the following actions would help you best determine internal stakeholders to achieve your goals using a risk-based approach?)

A minimum requirement for carrying out a Data Protection Impact Assessment (DPIA) would include?

Which of the following is elective when responding to a cross-jurisdictional breach of personal information?