D. Cultural norms.

Answer DescriptionExplanation:

In addition to regulatory requirements and business practices, an important factor that a global privacy strategy must consider is cultural norms. Different cultures may have different expectations and preferences regarding privacy, such as what constitutes personal information, how consent is obtained and expressed, how data is used and shared, and how privacy rights are enforced. A global privacy strategy should respect and accommodate these cultural differences and ensure that the organization’s privacy practices are transparent, fair, and consistent across different regions. References: [IAPP CIPM Study Guide], page 81-82; [Cultural Differences in Privacy Expectations]

D. Perform a privacy readiness assessment before the deal.

Answer DescriptionExplanation:

A privacy readiness assessment is not required during a data privacy diligence process for Merger & Acquisition (M&A) deals, as it is usually done before the deal to evaluate the privacy maturity and compliance level of the target organization. The other options are required during the data privacy diligence process to ensure that the personal data of both organizations are handled in accordance with the applicable laws and regulations, as well as the expectations of the data subjects and stakeholders. References: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 4: Manage data transfers.

C. The contact details of the Data Protection Officer (DPO).

D. The decrease of mean time to resolve privacy incidents

Answer DescriptionExplanation:

The decrease of mean time to resolve privacy incidents best demonstrates the effectiveness of a firm’s privacy incident response process. This metric measures how quickly and efficiently the firm can identify, contain, analyze, remediate, and report privacy incidents. A lower mean time to resolve indicates a higher level of preparedness, responsiveness, and resilience in handling privacy incidents. References: IAPP CIPM Study Guide, page 25.

C. Third-party audit.

Answer DescriptionExplanation:

A third-party audit would help an organization achieve the objective of demonstrating compliance with international privacy standards and identifying gaps for remediation. A third-party audit is an audit conducted by an independent and external auditor who is not affiliated with either the audited organization or its customers. A third-party audit can provide an objective and impartial assessment of the organization’s privacy practices and policies, as well as verify its compliance with relevant standards and regulations. A third-party audit can also help the organization identify areas for improvement and recommend corrective actions. A third-party audit can enhance the organization’s reputation, trustworthiness, and credibility among its stakeholders and customers.

A first-party audit is an audit conducted by the organization itself or by someone within the organization who has been designated as an auditor. A first-party audit is also known as an internal audit. A first-party audit can help the organization monitor its own performance, evaluate its compliance with internal policies and procedures, and identify potential risks and opportunities for improvement. However, a first-party audit may not be sufficient to demonstrate compliance with external standards and regulations, as it may lack independence and objectivity.

A second-party audit is an audit conducted by a party that has an interest in or a relationship with the audited organization, such as a customer, a supplier, or a partner. A second-party audit is also known as an external audit. A second-party audit can help the party verify that the audited organization meets its contractual obligations, expectations, and requirements. A second-party audit can also help the party evaluate the quality and reliability of the audited organization’s products or services. However, a second-party audit may not be able to provide a comprehensive and unbiased assessment of the audited organization’s privacy practices and policies, as it may be influenced by the party’s own interests and objectives. References: Types of Audits: 14 Types of Audits and Level of Assurance (2022)

B. The number of metrics should be limited at first.

Answer DescriptionExplanation:

A privacy professional should keep in mind that the number of metrics should be limited at first when selecting which metrics to collect. Metrics are quantitative measures that help evaluate the performance and effectiveness of a privacy program. However, collecting too many metrics can be overwhelming, confusing, and costly. Therefore, a privacy professional should start with a few key metrics that are relevant, meaningful, actionable, and aligned with the organization’s privacy goals and priorities. These metrics can be refined and expanded over time as the privacy program matures and evolves. References: [Privacy Metrics], [Measuring Privacy Program Effectiveness]

D. Provide a dedicated privacy space with the privacy policy, explanatory documents and operation frameworks.

Answer DescriptionExplanation:

Providing a dedicated privacy space with the privacy policy, explanatory documents and operation frameworks helps build trust with customers and stakeholders. A dedicated privacy space is a section on an organization’s website or app that provides clear and transparent information about how the organization processes personal information and respects data subject rights. It can include documents such as: a privacy policy that explains what personal information is collected, why it is collected, how it is used, who it is shared with, and how it is protected; explanatory documents that provide more details or examples of specific processing activities or scenarios; and operation frameworks that describe the procedures and mechanisms for data subject requests, complaints, inquiries, or feedback. A dedicated privacy space can help customers and stakeholders understand the organization’s privacy practices, choices, and values, and enhance their confidence and trust.

References:

• CIPM Body of Knowledge (2021), Domain II: Privacy Program Framework, Section A: Privacy
• Program Framework Components, Subsection 1: Privacy Policies
• CIPM Study Guide (2021), Chapter 4: Privacy Program Framework Components, Section 4.1: Privacy Policies
• CIPM Textbook (2019), Chapter 4: Privacy Program Framework Components, Section 4.1: Privacy Policies
• CIPM Practice Exam (2021), Question 140

B. Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released.

Answer DescriptionExplanation: Sanjay should work with Manasa to review and remediate the Handy Helper as a gating item before it is released. This means that Sanjay should collaborate with Manasa and her product team to evaluate the privacy implications of the product and address any gaps or issues before launching it in Europe. This could involve conducting a PIA, applying the PbD principles, revising the consent mechanism, updating the privacy notice, ensuring compliance with data localization requirements, implementing data security measures, and limiting data access based on the least privilege principle. By doing so, Sanjay could help minimize the risks of offering the product in Europe and avoid potential violations of the General Data Protection Regulation (GDPR) or other local laws that could result in fines, lawsuits, or loss of trust.