Isaca CDPSE - Certified Data Privacy Solutions Engineer

A third-party privacy control assessment is an independent and objective evaluation of the design and effectiveness of the privacy controls implemented by an organization to protect personal data and comply with privacy laws and regulations. A third-party privacy control assessment can help senior management to verify the success of its commitment to privacy by design, by providing the following benefits:

It can measure the extent to which the organization has adopted and integrated the principles and practices of privacy by design throughout its products, services, processes and systems.

It can identify the strengths and weaknesses of the organization’s privacy governance, policies, procedures, standards and guidelines, and provide recommendations for improvement.

It can validate the organization’s compliance with the applicable privacy requirements and expectations of its customers, stakeholders, regulators and auditors.

It can enhance the organization’s reputation and trustworthiness as a responsible and transparent data controller and processor.

The other options are less effective or irrelevant for verifying the success of the commitment to privacy by design. Reviewing the findings of an industry benchmarking assessment may provide some insights into how the organization compares with its peers or competitors in terms of privacy performance, but it may not reflect the specific privacy goals, risks and challenges of the organization. Identifying trends in the organization’s amount of compromised personal data or number of privacy incidents may indicate some aspects of the organization’s privacy maturity, but they are reactive and lagging indicators that do not capture the proactive and preventive nature of privacy by design. Moreover, these metrics may not account for other factors that may influence the occurrence or impact of data breaches or privacy violations, such as external threats, human errors or environmental changes.

The primary reason that a single cryptographic key should be used for only one purpose, such as encryption or authentication, is that it minimizes the risk if the cryptographic key is compromised. A cryptographic key is a piece of information that is used to perform cryptographic operations, such as encryption or authentication. Encryption is a process of transforming data into an unreadable form using a secret key or algorithm. Authentication is a process of verifying the identity or integrity of a user or data using a secret key or algorithm. If a single cryptographic key is used for multiple purposes, such as encryption and authentication, it increases the risk if the cryptographic key is compromised. For example, if an attacker obtains the cryptographic key that is used for both encryption and authentication, they can decrypt and access personal data, as well as impersonate or modify legitimate users or data. Therefore, a single cryptographic key should be used for only one purpose, and different keys should be used for different purposes. References: : CDPSE Review Manual (Digital Version), page 107

The best way to maintain the quality of personal data is to implement routine automatic validation, which is a process of checking the accuracy, completeness, consistency, and timeliness of the data using automated tools or scripts. Routine automatic validation can help identify and correct any errors, anomalies, or discrepancies in the data, as well as ensure that the data meets the specified quality standards and requirements. Routine automatic validation can also help improve the efficiency and reliability of the data processing and analysis12.

The most effective way to support organizational privacy awareness objectives is D. Customizing awareness training by business unit function.

A comprehensive explanation is:

Organizational privacy awareness objectives are the goals and expectations that an organization sets for its employees and stakeholders regarding the protection and management of personal data. Privacy awareness objectives may vary depending on the nature, scope, and purpose of the organization’s data processing activities, as well as the legal, regulatory, contractual, and ethical obligations and implications that apply to them.

One of the best practices to support organizational privacy awareness objectives is to customize awareness training by business unit function. This means that the organization should design and deliver privacy awareness training programs that are tailored to the specific roles, responsibilities, and needs of each business unit or department within the organization. Customizing awareness training by business unit function can have several benefits, such as:

Enhancing the relevance and effectiveness of the training content and methods for each audience group, by addressing their specific privacy challenges, risks, and opportunities.

Increasing the engagement and motivation of the trainees, by showing them how privacy relates to their daily tasks, goals, and performance.

Improving the retention and application of the training knowledge and skills, by providing practical examples, scenarios, and exercises that reflect the real-world situations and problems that the trainees may encounter.

Fostering a culture of privacy across the organization, by creating a common language and understanding of privacy concepts, principles, and practices among different business units or departments.

Some examples of how to customize awareness training by business unit function are:

Providing different levels or modules of training based on the degree of access or exposure to personal data that each business unit or department has. For example, a basic level of training for all employees, an intermediate level of training for employees who handle personal data occasionally or incidentally, and an advanced level of training for employees who handle personal data regularly or extensively.

Providing different topics or themes of training based on the type or category of personal data that each business unit or department processes. For example, a general topic of training for employees who process non-sensitive or non-personal data, a specific topic of training for employees who process sensitive or special data categories (such as health, biometric, financial, or political data), and a specialized topic of training for employees who process high-risk or high-value data (such as intellectual property, trade secrets, or customer loyalty data).

Providing different formats or modes of training based on the preferences or constraints of each business unit or department. For example, a face-to-face format of training for employees who work in the same location or office, an online format of training for employees who work remotely or across different time zones, and a blended format of training for employees who work in a hybrid mode or have flexible schedules.

The other options are not as effective as option D.

Funding in-depth training and awareness education for data privacy staff (A) may improve the competence and confidence of the data privacy staff who are responsible for designing and implementing the privacy policies and practices of the organization, but it does not necessarily support the organizational privacy awareness objectives for the rest of the employees and stakeholders.

Implementing an annual training certification process (B) may ensure that the employees and stakeholders are updated and refreshed on the privacy policies and practices of the organization on a regular basis, but it does not necessarily address their specific privacy needs and challenges based on their business unit function.

Including mandatory awareness training as part of performance evaluations © may incentivize the employees and stakeholders to participate in and complete the privacy awareness training programs offered by the organization, but it does not necessarily enhance their understanding and application of privacy concepts and principles based on their business unit function.

Anonymization is a technique that removes or modifies personal data in such a way that it can no longer be attributed to a specific data subject. Anonymization can be achieved by various methods, such as encryption, pseudonymization, aggregation, generalization, etc. When using anonymization techniques to prevent unauthorized access to personal data, the most important consideration to ensure the data is adequately protected is that the key must be kept separate and distinct from the data it protects. The key is a piece of information that is used to reverse the anonymization process and restore the original personal data. The key must be stored and managed in a secure location that is different from where the anonymized data is stored and processed. This way, even if the anonymized data is compromised, the key cannot be accessed or used to re-identify the data subjects. References: : CDPSE Review Manual (Digital Version), page 29

Online behavioral tracking is a tracking technology associated with unsolicited targeted advertisements that presents the greatest privacy risk. Online behavioral tracking is a technique that collects and analyzes personal data about users’ online activities, preferences, interests, and behaviors across different websites or platforms. Online behavioral tracking is used to create user profiles and deliver personalized or targeted advertisements that match users’ needs or wants. Online behavioral tracking poses a privacy risk because it can invade users’ privacy by collecting sensitive or intimate personal data without their knowledge or consent, such as health conditions, political views, sexual orientation, etc. Online behavioral tracking can also expose users to unwanted or inappropriate advertisements that may influence their decisions or actions. References: : CDPSE Review Manual (Digital Version), page 139

The primary means by which an organization communicates customer rights as it relates to the use of their personal information is publishing a privacy notice. A privacy notice is a document that informs the customers about how the organization collects, uses, shares, and protects their personal information, and what rights and choices they have regarding their data4. A privacy notice is a legal requirement under many data protection laws and regulations, such as the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), or the Personal Information Protection and Electronic Documents Act (PIPEDA)5 . A privacy notice is also a good practice to demonstrate the organization’s commitment to transparency, accountability, and customer trust. References:

ISACA Glossary of Terms

Article 13 and 14 of the GDPR

[Section 1798.100 of the CCPA]

[Schedule 1, Principle 4.8 of the PIPEDA]

[ISACA CDPSE Review Manual, Chapter 1, Section 1.3.2]

A multinational organization that operates across different countries and regions should perform an annual review of changes to privacy regulations in all jurisdictions where its corporate data is processed. This is because different jurisdictions may have different privacy laws and requirements that apply to the collection, use, storage, transfer, and disposal of personal data. For example, the EU General Data Protection Regulation (GDPR) applies to any organization that processes personal data of individuals in the EU, regardless of where the organization is located or where the data is processed. Therefore, the organization should keep track of the changes to privacy regulations in all relevant jurisdictions and update its data privacy policy accordingly to ensure compliance and avoid penalties or lawsuits.