Isaca CDPSE - Certified Data Privacy Solutions Engineer

Data flow diagrams (DFDs) are most valuable for illustrating the locations and movements of personal data across systems and processes, which is essential for compliance mapping and controls. Mapping at rest (C) or transit (D) are subsets of this broader view, while (A) is vague.

“DFDs identify where personal data resides and flows, supporting compliance and risk management.”

Application hardening measures are the most important action to protect a mobile banking app and its data against manipulation and disclosure because they prevent attackers from reverse engineering, tampering, or injecting malicious code into the app. Application hardening measures include techniques such as code obfuscation, encryption, integrity checks, anti-debugging, and anti-tampering mechanisms. These measures make the app more resilient and secure against various types of cyberattacks.

A virtual private network (VPN) is a technology that creates a secure and encrypted connection over a public network, such as the internet. A VPN should be established first before authorizing remote access to a data store containing personal data, as it protects the data from unauthorized interception, modification, or disclosure by third parties. A VPN also helps to ensure the identity and authenticity of the remote users and devices accessing the data store. References: 2 Domain 2, Task 8

A privacy risk assessment is a process of identifying, analyzing and evaluating the privacy risks associated with the collection, use, disclosure or retention of personal data. A privacy risk assessment is the best way to distinguish between a privacy risk and compliance risk, as it would help to determine the likelihood and impact of privacy incidents or breaches that could affect the rights and interests of the data subjects, as well as the legal obligations and responsibilities of the organization. A privacy risk assessment would also help to identify and implement appropriate controls and measures to mitigate or reduce the privacy risks and ensure compliance with privacy principles, laws and regulations. The other options are not as effective as conducting a privacy risk assessment in distinguishing between a privacy risk and compliance risk. Performing a privacy risk audit is a process of verifying and validating the effectiveness and adequacy of the privacy controls and measures implemented by the organization, but it does not necessarily identify or evaluate the privacy risks or compliance risks. Validating a privacy risk attestation is a process of confirming and certifying the accuracy and completeness of the privacy information or statements provided by the organization, but it does not necessarily identify or evaluate the privacy risks or compliance risks. Conducting a privacy risk remediation exercise is a process of implementing corrective actions or improvements to address the identified or reported privacy risks or compliance risks, but it does not necessarily distinguish between them1, p. 66-67 References: 1: CDPSE Review Manual (Digital Version)

One of the most common vulnerabilities that can compromise the access to personal information is end users using weak passwords. Weak passwords are passwords that are easy to guess, crack, or steal, such as passwords that are short, simple, common, or reused. Weak passwords can allow unauthorized or malicious parties to gain access to personal information and cause privacy breaches, leaks, or misuse. Multi-factor authentication is an effective way to mitigate this vulnerability, as it requires end users to provide more than one piece of evidence to verify their identity, such as something they know (e.g., password), something they have (e.g., token), or something they are (e.g., biometric). Multi-factor authentication makes it harder for attackers to bypass the authentication process and access personal information. References: : CDPSE Review Manual (Digital Version), page 107

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.

A privacy impact assessment (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 done first to address privacy risk when migrating customer relationship management (CRM) data to a new system, as it would help to ensure that privacy risks are identified and mitigated before the migration is executed. A PIA would also help to ensure compliance with privacy principles, laws and regulations, and alignment with customer expectations and preferences. The other options are not as important as performing a PIA when addressing privacy risk when migrating CRM data to a new system. Developing a data migration plan is a process of defining and documenting the objectives, scope, approach, methods and steps for transferring data from one system to another, but it does not necessarily address privacy risk or impact. Conducting a legitimate interest analysis (LIA) is a process of assessing whether there is a legitimate interest for processing personal data that outweighs the rights and interests of the data subjects, but it is only applicable in certain jurisdictions and situations where legitimate interest is a valid legal basis for processing. Obtaining consent from data subjects is a process of obtaining their permission or agreement before collecting, using, disclosing or transferring their personal data for specific purposes, but it may not be required or sufficient for migrating CRM data to a new system, depending on the context and nature of the migration and the applicable laws and regulations1, p. 67 References: 1: CDPSE Review Manual (Digital Version)

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.

Prioritizing privacy-related risk scenarios as part of ERM processes is the best way to ensure that the risk responses meet the organizational objectives, because it helps to align the privacy risk management with the overall strategic goals, values, and culture of the organization. ERM is a holistic approach to identify, assess, and manage risks across the organization, taking into account the interdependencies and trade-offs among different types of risks. By integrating privacy-related risk scenarios into the ERM processes, the organization can evaluate the potential impact and likelihood of privacy risks on its mission, vision, and performance, and prioritize the most significant ones for mitigation or acceptance. This can also help to allocate appropriate resources, assign clear roles and responsibilities, and monitor and report on the effectiveness of the risk responses.

Collecting more data than necessary for recruitment violates the principle of data minimization, which requires limiting collection to what is adequate, relevant, and necessary. Transparency (A) deals with notice, localization (B) concerns storage jurisdiction, and quality (D) addresses accuracy.

“Data minimization: collect and process only the data that is necessary for the stated purpose.”