Isaca CDPSE - Certified Data Privacy Solutions Engineer

A raw zone is a zone within a data lake that contains unprocessed or unstructured data that is ingested from various sources without any transformation or validation. A raw zone may contain sensitive data that has not been identified or classified yet, such as personal data. Therefore, sensitive data in a raw zone should be encrypted or tokenized to protect its confidentiality and integrity. Encryption is a process of transforming data into an unreadable form using a secret key or algorithm. Tokenization is a process of replacing sensitive data with non-sensitive substitutes called tokens. Both encryption and tokenization help to prevent unauthorized or unlawful access, use, disclosure, or transfer of sensitive data in a raw zone. References: : CDPSE Review Manual (Digital Version), page 169

Compartmentalizing resource access is a security technique that divides a system or network into separate segments or zones with different levels of access and control, based on the sensitivity and value of the data or resources. Compartmentalizing resource access would most effectively reduce the impact of a successful breach through a remote access solution, as it would limit the scope and extent of the breach, and prevent unauthorized access to other segments or zones that contain more critical or sensitive data or resources. The other options are not as effective as compartmentalizing resource access in reducing the impact of a successful breach through a remote access solution. Regular testing of system backups is a security technique that verifies the availability and recoverability of data in case of a system failure or disaster, but it does not prevent or limit unauthorized access to data. Monitoring and reviewing remote access logs is a security technique that records and analyzes the activities and events related to remote access sessions, but it does not prevent or limit unauthorized access to data. Regular physical and remote testing of the incident response plan is a security technique that evaluates and improves the readiness and effectiveness of an organization’s response to security incidents, but it does not prevent or limit unauthorized access to data1, p. 91-92 References: 1: CDPSE Review Manual (Digital Version)

Remote employee monitoring software is a solution that collects, analyzes and reports data on the activities and behaviors of employees who work remotely or from home. It can help organizations to measure and improve employee productivity, performance, engagement and security. However, it also poses significant privacy risks and challenges, as it may involve the collection and processing of personal data, such as names, email addresses, biometric data, IP addresses, keystrokes, screenshots, web browsing history, app usage, communication content and frequency, etc.

Data access should be restricted based on roles, meaning that only authorized and legitimate parties should be able to access and use the data collected by the remote employee monitoring software, based on their roles and responsibilities within the organization. This is a key privacy principle and practice that helps to protect the privacy rights and interests of the employees, and to prevent unauthorized or excessive access, use, disclosure or modification of their personal data by the organization or third parties. Data access restriction based on roles 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.

References:

Mobile Workforce Security Considerations and Privacy - ISACA, section 3: “The principle of least privilege should be applied to ensure that only authorized personnel have access to the data.”

Why Employee Privacy Matters More Than Ever - ISACA, section 3: “Privacy-first monitoring should include granular privacy controls, including: Auto-redacting personal information; Restricting access to sensitive information based on role; Masking sensitive information from view.”

A legal review is the most important thing to ensure before executive leadership approves a new data privacy policy, as it would help to verify and validate the accuracy, completeness and compliance of the policy with the applicable laws and regulations that govern the collection, use, disclosure and transfer of personal data. A legal review would also help to identify and address any gaps, inconsistencies or conflicts in the policy, and to provide legal advice or guidance on the implementation and enforcement of the policy. The other options are not as important as a legal review in ensuring before executive leadership approves a new data privacy policy. A training program is a method of educating and informing the employees and stakeholders about the new data privacy policy, its objectives, requirements and implications, but it does not ensure the quality or compliance of the policy itself. A privacy committee is a group of individuals who are responsible for overseeing, monitoring and evaluating the organization’s data privacy program, policies and practices, but it does not ensure the quality or compliance of the policy itself. A distribution methodology is a method of disseminating and communicating the new data privacy policy to the employees and stakeholders, such as email, intranet, website or newsletter, but it does not ensure the quality or compliance of the policy itself1, p. 98 References: 1: CDPSE Review Manual (Digital Version)

Validation and certification of data destruction is the most important consideration when choosing a method for data destruction, because it provides evidence that the data has been destroyed beyond recovery and that the organization has complied with the applicable information security frameworks and legal requirements. Validation and certification can also help to prevent data breaches, avoid legal liabilities, and enhance the organization’s reputation and trustworthiness. Different methods of data destruction may have different levels of validation and certification, depending on the type of media, the sensitivity of the data, and the standards and guidelines followed. For example, some methods may require a third-party verification or audit, while others may generate a certificate of destruction or a report of erasure. Therefore, the organization should choose a method that can provide sufficient validation and certification for its specific needs and obligations.

References:

Secure Data Disposal and Destruction: 6 Methods to Follow, KirkpatrickPrice

Data Destruction Standards and Guidelines, BitRaser

Best Practices for Data Destruction, U.S. Department of Education

In GDPR parlance, organizations that use third-party service providers are often, but not always, considered data controllers, which are entities that determine the purposes and means of the processing of personal data, which can include directing third parties to process personal data on their behalf. The third parties that process data for data controllers are known as data processors.

The best way to protect personal data in the custody of a third party is to include requirements to comply with the organization’s privacy policies in the contract. This means that the organization should specify the terms and conditions of data processing, such as the purpose, scope, duration, and security measures, and ensure that they are consistent with the organization’s privacy policies and applicable privacy regulations. The contract should also define the roles and responsibilities of both parties, such as data controller and data processor, and establish mechanisms for monitoring, reporting, auditing, and resolving any issues or incidents related to data privacy. References: : CDPSE Review Manual (Digital Version), page 41

The most important information to capture in the audit log of an application hosting personal data is the last user who accessed personal data. This is because the audit log is a record of the activities and events that occur within the application, such as user actions, system events, errors, or exceptions. The audit log helps to monitor and verify the compliance, security, and performance of the application, as well as to detect and investigate any incidents or anomalies. Capturing the last user who accessed personal data in the audit log helps to ensure the accountability and traceability of the data access, as well as to identify and prevent any unauthorized or inappropriate use, disclosure, or modification of personal data.

References: CDPSE Review Manual, 2021, p. 147

Data retention is a process of keeping personal data for a specified period of time for legitimate purposes, such as legal obligations, contractual agreements, business operations or historical records. Data retention should be based on the principle of data minimization, which requires limiting the collection, storage and processing of personal data to what is necessary and relevant for the intended purposes. Data retention should also comply with the principle of storage limitation, which requires deleting or disposing of personal data when it is no longer needed or justified. The most likely valid use case for keeping a customer’s personal data after contract termination is a required retention period due to regulations, such as tax laws, financial laws, health laws or consumer protection laws, that mandate the organization to retain certain types of customer data for a certain period of time after the end of the contractual relationship. The other options are not valid use cases for keeping a customer’s personal data after contract termination, as they do not meet the criteria of necessity, relevance or justification. For the purpose of medical research, the organization would need to obtain the consent of the customer or have another legal basis for processing their personal data for a different purpose than the original contract. A forthcoming campaign to win back customers or ease of onboarding when the customer returns are not legitimate purposes for retaining customer data after contract termination, as they are not related to the original contract and may violate the customer’s privacy rights and preferences. , p. 99-100 References: : CDPSE Review Manual (Digital Version)

The best way for an organization to ensure its vendors are complying with data privacy requirements defined in their contracts is to obtain independent assessments of the vendors’ data management processes, because this will provide an objective and reliable evaluation of the vendors’ privacy practices, policies, and controls. Independent assessments can be performed by external auditors, consultants, or certification bodies that have the expertise and credibility to verify the vendors’ compliance with the contractual obligations and expectations. Independent assessments can also help identify and address any privacy risks or gaps that may arise from the vendors’ 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.