Isaca CDPSE - Certified Data Privacy Solutions Engineer

The value proposition of a PIA is not understood by management is the greatest obstacle to conducting a PIA, as it may result in lack of support, funding, resources or commitment for the PIA process and outcomes. Management may not appreciate or recognize the benefits of a PIA, such as enhancing privacy protection, reducing privacy risks and costs, increasing customer trust and satisfaction, and complying with privacy laws and regulations. Management may also perceive a PIA as a burden, a delay or a hindrance to the system or project development and delivery. The other options are not as significant as the value proposition of a PIA is not understood by management as obstacles to conducting a PIA. Conducting a PIA requires significant funding and resources is an obstacle to conducting a PIA, but it may be overcome by demonstrating the return on investment or the cost-benefit analysis of a PIA. PIAs need to be performed many times in a year is an obstacle to conducting a PIA, but it may be mitigated by adopting a scalable or modular approach to PIAs that can be tailored to different types or levels of systems or projects. The organization lacks knowledge of PIA methodology is an obstacle to conducting a PIA, but it may be resolved by acquiring or developing the necessary skills, tools or guidance for performing PIAs1, p. 67-68 References: 1: CDPSE Review Manual (Digital Version)

Collecting only the data necessary to meet objectives is the best approach to minimize privacy risk when collecting personal data. This is based on the principle of data minimization, which states that personal data should be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed. Using a third party, collecting data through a secure web server, or aggregating data immediately may reduce some privacy risks, but they do not eliminate the possibility of collecting excessive or unnecessary data. References: CDPSE Exam Content Outline, Domain 3, Task 3.2

The best way to address the concern that data collected by a third-party vendor and provided back to the organization may not be protected according to the organization’s privacy notice is to validate contract compliance. This means that the organization should verify that the third-party vendor is adhering to the terms and conditions of the contract, which should include clauses on data protection, privacy, and security. The contract should also specify the obligations and responsibilities of both parties regarding data collection, processing, storage, transfer, retention, and disposal. By validating contract compliance, the organization can ensure that the third-party vendor is following the same privacy standards and practices as the organization.

The most important thing to consider when managing changes to the provision of services by a third party that processes personal data is the business impact due to the changes. Changes to the provision of services by a third party can affect the organization’s ability to meet its business objectives and legal obligations related to data processing activities. For example, changes to the service level agreement (SLA), the scope of services, the security measures, the location of servers, etc., can have implications for the quality, availability, confidentiality, integrity, and compliance of personal data processing. Therefore, an IT privacy practitioner should assess and evaluate the business impact due to the changes, and ensure that they are aligned with the organization’s privacy policies and applicable privacy regulations and standards. References: : CDPSE Review Manual (Digital Version), page 41

The scenario that poses the greatest risk to an organization from a privacy perspective is that the organization lacks a hardware disposal policy. A hardware disposal policy is a policy that defines how the organization should dispose of or destroy hardware devices that contain or process personal data, such as laptops, servers, hard drives, USBs, etc. A hardware disposal policy should ensure that personal data is securely erased or overwritten before the hardware device is discarded, recycled, donated, or sold. A hardware disposal policy should also comply with the applicable privacy regulations and standards that govern data retention and destruction. By lacking a hardware disposal policy, the organization exposes personal data to potential threats, such as theft, loss, or unauthorized access, use, disclosure, or transfer. References: : CDPSE Review Manual (Digital Version), page 123

System hardening is a process of applying security measures and configurations to a system to reduce its attack surface and enhance its resistance to threats. System hardening can include disabling unnecessary services, removing default accounts, applying patches and updates, enforcing strong passwords and encryption, and implementing firewalls and antivirus software. The primary benefit of system hardening is that it increases system resiliency, which is the ability of a system to withstand or recover from adverse events that could affect its functionality or performance. The other options are not the primary benefits of system hardening, although they may be secondary benefits or outcomes. System hardening does not necessarily reduce external threats to data, as threats can originate from various sources and vectors. System hardening may reduce exposure of data, but only if the data is stored or processed by the system. System hardening does not eliminate attack motivation for data, as attackers may have different motives and incentives for targeting data. , p. 91-92 References: : CDPSE Review Manual (Digital Version)

Some organizations, typically those that manage large amounts of personal information related to employees, customers, or constituents, will employ a chief privacy officer (CPO). Some organizations have a CPO because applicable regulations such as the Gramm-Leach-Bliley Act (GLBA) require it. Other regulations such as the Health Information Portability and Accountability Act (HIPAA), the Fair Credit Reporting Act (FCRA), and the GLBA place a slate of responsibilities upon an organization that compels them to hire an executive responsible for overseeing compliance.

The chief privacy officer (CPO) is the senior executive who is responsible for establishing and maintaining the organization’s privacy vision, strategy, and program. The CPO oversees the development and implementation of privacy policies, procedures, standards, and controls, and ensures that they align with the organization’s business objectives and legal obligations. The CPO also leads the privacy governance structure, such as the privacy steering committee, and coordinates with other stakeholders, such as the chief data officer (CDO), the information security steering committee, and the legal counsel, to ensure that privacy is integrated into all aspects of the organization’s operations. References: : CDPSE Review Manual (Digital Version), page 21

Requiring independent audits of the providers’ data privacy controls is the best way to ensure third-party providers that process an organization’s personal data are addressed as part of the data privacy strategy. Independent audits can verify that the providers are complying with the applicable data privacy laws and regulations, as well as the organization’s own policies and standards. Independent audits can also identify any gaps or weaknesses in the providers’ data privacy controls and recommend corrective actions or improvements.