IAPP CIPT - Certified Information Privacy Technologist

The first privacy framework to be developed was the OECD Privacy Principles. These principles were introduced by the Organization for Economic Co-operation and Development (OECD) in 1980 and laid the groundwork for many subsequent privacy laws and regulations. The OECD Privacy Principles include guidelines on data collection, data quality, purpose specification, use limitation, security safeguards, openness, individual participation, and accountability. These principles have had a significant influence on the development of privacy practices worldwide (IAPP, Certified Information Privacy Technologist (CIPT) materials).

ï‚· Definition: Information classification involves categorizing information based on its level of sensitivity and the impact to the organization if it is disclosed, altered, or destroyed.

ï‚· Purpose: This classification helps in identifying which information requires more stringent protection measures.

ï‚· Application: Once classified, appropriate security controls (technical, administrative, and physical) can be applied to safeguard the information accordingly.

ï‚· References: IAPP CIPT Study Guide, Section on Information Classification and Handling.

Sophisticated Access Management (AM) techniques focus on controlling who can access certain data and under what conditions. Techniques such as restricting access based on location (A), user role (B), and device type (C) are common in access management systems. However, preventing data from being placed in unprotected storage (D) falls more under data security and protection measures rather than access management. AM primarily addresses the question of who has access and how, whereas ensuring that data is stored securely involves encryption, secure storage solutions, and proper configuration management, which are typically beyond the scope of AM systems. This distinction is made clear in various security and privacy guidelines, including those provided by the IAPP and the National Institute of Standards and Technology (NIST).

A workplace surveillance policy should outline critical aspects such as who can be tracked and when, who can access the surveillance data, and what areas can be placed under surveillance. However, detailing who benefits from collecting the surveillance data is not typically included as it may not directly relate to privacy and security policies but rather to internal policy discussions.

Option A (Implementing privacy elements for visually-challenged users): This demonstrates respect to user privacy by ensuring that technology is accessible to all users, including those with disabilities. It aligns with the principle of inclusivity and respect for all users.

Option B (Enabling DSARs): This directly respects user privacy by allowing individuals to exercise their rights to access, correct, delete, amend, and rectify their personal information. It is a core aspect of privacy rights under regulations like GDPR.

Option C (Consent management portal): Providing a consent management self-service portal allows users to review and manage their consent preferences. This empowers users with control over their personal data, which is a key aspect of respecting user privacy.

Option D (Filing breach notification paperwork): Filing breach notification paperwork with data protection authorities is a compliance activity rather than an illustration of respect for user privacy. While it is necessary and legally required, it does not directly interact with or respect user privacy principles in the same way as the other options.

References:

GDPR Articles on Data Subject Rights (Articles 15-22).

Principles of Privacy by Design and Respect for User Privacy (Ann Cavoukian’s 7 Foundational Principles).

Conclusion: Filing breach notification paperwork with data protection authorities (Option D) is a necessary compliance activity but does not directly illustrate the ‘respect to user privacy’ principle in the same way as the other options.

The scenario where a user clicks to accept cookies and then continues to scroll the page is an example of implicit consent. Implicit consent refers to consent that is inferred from a user's actions rather than explicitly stated. In this case, the user's action of clicking to accept cookies and continuing to use the site implies their agreement to the terms outlined in the privacy notice. (Reference: IAPP CIPT Study Guide, Chapter on Consent Mechanisms)

To effectively facilitate the deletion of every instance of data associated with a deleted user account from all data stores, the most reliable approach is to build a standardized and documented retention program for user data deletion. This program ensures a systematic process for identifying and removing user data across all data stores in the organization, ensuring compliance with data protection principles. By having a documented policy, the organization can maintain consistency and accountability in data deletion processes. This method is recommended by data privacy standards and is elaborated in IAPP’s Information Privacy Technologist resources.

Risk transfer involves shifting the potential negative consequences of a risk to a third party. By purchasing insurance, an organization transfers the financial risk associated with a data breach to the insurance company. This is a common practice to mitigate the impact of data breaches.

References:

IAPP CIPT Study Guide: Risk Management and Data Breaches.

IAPP Certified Information Privacy Technologist (CIPT) Handbook: Section on Risk Management.

ï‚· Problem Identification: Recording patient data on a mobile phone's note-taking application poses a significant privacy risk.

ï‚· Solution: Mobile Device Management (MDM) can enforce security policies, such as encryption, secure app installation, and remote wiping of data.

 Benefits: MDM ensures that all devices comply with the organization’s security standards, thereby protecting sensitive health information.

ï‚· References: IAPP CIPT Study Guide, Section on Mobile Device Security and Management.

Building a system with user access controls and approval workflows to edit customer data is considered the best method for an organization to achieve the privacy principle of data quality. This approach ensures that data is accurate, complete, and up-to-date by allowing controlled access and modifications. The IAPP’s CIPT materials discuss data quality principles, emphasizing the importance of implementing robust data management practices to maintain data integrity and accuracy.