Isaca CDPSE - Certified Data Privacy Solutions Engineer

A primary objective of performing a privacy impact assessment (PIA) prior to onboarding a new Software as a Service (SaaS) provider for a customer relationship management (CRM) system is to identify controls to mitigate data privacy risks, such as data breaches, unauthorized access, misuse or loss of data. A PIA would help to evaluate the potential privacy impacts of using a new SaaS provider for CRM data processing activities, such as collecting, storing, analyzing or transferring customer data, and to implement appropriate controls to mitigate those impacts, such as encryption, access control, backup, audit trail or contractual clauses. 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 primary objectives of performing a PIA prior to onboarding a new SaaS provider for CRM data processing activities. Classifying personal data according to the data classification scheme is an activity that may be part of a PIA process, but it is not an objective in itself. Assessing the risk associated with personal data usage is an activity that may be part of a PIA process, but it is not an objective in itself. Determining the service provider’s ability to maintain data protection controls is an activity that may be part of a PIA process, but it is not an objective in itself1, p. 67 References: 1: CDPSE Review Manual (Digital Version)

User consent to share personal data is the most important factor when designing APIs that enable mobile device applications to access personal data, as it ensures that the user is informed and agrees to the purpose, scope, and duration of the data sharing. User consent also helps to comply with the data protection principles and regulations, such as the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), that require user consent for certain types of data processing and sharing134. References: 1 Domain 2, Task 7

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

De-identification is a technique that removes or modifies direct and indirect identifiers in a data set to prevent or limit the identification of the data subjects. De-identification reduces the risk of re-identification and thus limits the organization’s potential exposure in the event of consumer data loss. De-identification also maintains the traceability of the data by preserving some characteristics or patterns of the original data that can be used for analysis or research purposes. The other options are not effective ways to limit exposure and maintain traceability1, p. 75-76 References: 1: CDPSE Review Manual (Digital Version)

A bug bounty program is an assurance approach that involves offering rewards to external security researchers who find and report vulnerabilities in an API or other software. A bug bounty program can be more effective than other assurance approaches in identifying API vulnerabilities because it leverages the skills, creativity, and diversity of a large pool of ethical hackers who can test the API from different perspectives and scenarios. A bug bounty program can also incentivize continuous testing and reporting of vulnerabilities, which can help improve the security posture of the API over time.

References:

10 top API security testing tools, CSO Online

Bug Bounty Programs: What You Need to Know, ISACA Journal

 Including privacy requirements in vendor contracts is the best way to ensure privacy considerations are included when working with vendors because it establishes the obligations, expectations and responsibilities of both parties regarding the protection of personal data. It also provides a legal basis for enforcing compliance and resolving disputes. Including privacy requirements in the request for proposal (RFP) process, monitoring privacy-related service level agreements (SLAs) and requiring vendors to complete privacy awareness training are helpful measures, but they do not guarantee that vendors will adhere to the privacy requirements or that they will be held accountable for any violations.

References:

CDPSE Review Manual (Digital Version), Domain 1: Privacy Governance, Task 1.7: Participate in the management and evaluation of contracts, service levels and practices of vendors and other external parties1

CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 2: Privacy Governance, Section: Vendor Management2

Degaussing is a hard drive sanitation method that uses a powerful magnetic field to erase or destroy the data stored on a magnetic disk or tape. Degaussing should be used to sanitize hard drives containing personal data prior to being crushed, as it provides an additional layer of assurance that data has been permanently erased and cannot be recovered by any means. Degaussing also damages the drive itself, making it unusable for future storage. The other options are not effective or necessary hard drive sanitation methods prior to being crushed. Low-level formatting is a hard drive sanitation method that erases the data and the partition table on the drive, but it may leave some traces of data that can be recovered by forensic tools or software. Remote partitioning is a hard drive sanitation method that creates separate logical sections on the drive, but it does not erase or destroy the data on the drive. Hammer strike is a hard drive sanitation method that physically damages the drive by hitting it with a hammer, but it may not erase or destroy the data completely or prevent data recovery by advanced tools or techniques1, p. 93-94 References: 1: CDPSE Review Manual (Digital Version)

The best way to address privacy concerns when an organization captures personal data from a third party through an open application programming interface (API) is to obtain consent from the data subjects. Consent is a freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they agree to the processing of their personal data by the organization for a defined purpose. Consent is one of the legal bases for processing personal data under various privacy laws and regulations such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA). Obtaining consent from the data subjects can help ensure that they are aware of and agree to the collection and use of their personal data by the organization through the open API. Obtaining consent can also help respect the data subject’s rights and preferences regarding their personal data.

Developing a service level agreement (SLA) with the third party, implementing encryption for the data transmission, or reviewing the specification document of the open API are also good practices for addressing privacy concerns when using an open API to capture personal data from a third party, but they are not the best way. Developing an SLA with the third party can help define the roles, responsibilities, expectations, and obligations of both parties regarding the provision and use of the open API and the personal data involved. Implementing encryption for the data transmission can help protect the confidentiality, integrity, and availability of the personal data transferred between the third party and the organization through the open API. Reviewing the specification document of the open API can help understand the functionality, features, parameters, or requirements of the open API and how it handles personal data.

References: Open APIs and Security Risks | Govenda Board Portal Software, The top API security risks and how to mitigate them - Appinventiv, Critical API security risks: 10 best practices | TechBeacon