D. A single attribute

Answer DescriptionExplanation:

A single attribute is a term that describes a piece of personal data that alone may not identify an individual, such as a first name or a zip code. However, when combined with other attributes, it may become identifiable. References: IAPP CIPM Study Guide, page 18.

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

B. Training on local laws must be implemented for all personnel.

Answer DescriptionExplanation: This answer is the best way to illustrate the training requirements for privacy protection, as it shows the importance of understanding and complying with the different legal and regulatory frameworks that apply to the organization’s data processing activities in different jurisdictions. Training on local laws must be implemented for all personnel who are involved in or responsible for collecting, using, disclosing, storing or transferring personal data across borders, as they may face different obligations and restrictions depending on the nature and location of the data and the data subjects. Training on local laws can help to prevent or mitigate the risks of violating the privacy rights of individuals, facing legal actions, fines, sanctions or investigations from authorities, or losing trust and reputation among customers, partners and stakeholders.

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)

D. Distribute a phishing exercise to all employees to test their ability to recognize a threat attempt.

Answer DescriptionExplanation: Distributing a phishing exercise to all employees is not advisable to do if your organization has a recurring issue with colleagues not reporting personal data breaches. A phishing exercise is a simulated attack that tests the awareness and response of employees to malicious emails that attempt to obtain sensitive information or compromise systems. While phishing exercises can be useful to train employees on how to recognize and avoid phishing attacks, they are not directly related to the issue of reporting personal data breaches. The other options are more appropriate to address the root cause of the issue, communicate the expectations and procedures for reporting breaches, and provide specific training to areas where breaches are happening.

A. The Board of Directors.

Answer DescriptionExplanation:

If an organization maintains a separate ethics office, its officer would typically report to the Board of Directors in order to retain the greatest degree of independence. This is because the Board of Directors is the highest governing body of the organization and has the authority and responsibility to oversee the ethical conduct and performance of the organization and its management1 Reporting to the Board of Directors would enable the ethics officer to avoid any potential conflicts of interest or undue influence from other senior executives or managers who may have a stake in the ethical issues or decisions that the ethics office handles2 Reporting to the Board of Directors would also enhance the credibility and legitimacy of the ethics office and its recommendations, as well as demonstrate the organization’s commitment to ethical values and culture3

The other options are not as suitable as reporting to the Board of Directors for retaining the greatest degree of independence for the ethics office. Reporting to the Chief Financial Officer may create a conflict of interest or a perception of bias if the ethical issues or decisions involve financial matters or implications4 Reporting to the Human Resources Director may limit the scope or authority of the ethics office to deal with ethical issues or decisions that go beyond human resources policies or practices5 Reporting to the organization’s General Counsel may blur the distinction or create confusion between legal compliance and ethical conduct, as well as raise concerns about attorney-client privilege or confidentiality6 References: 1: Board Responsibilities | BoardSource; 2: Ethics Officer: Job Description, Duties and Requirements; 3: The Role Of The Ethics And Compliance Officer In The 21st Century | Corporate Compliance Insights; 4: Ethics Officer: Job Description, Duties and Requirements; 5: Ethics Officer: Job Description, Duties and Requirements; 6: Ethics Officer: Job Description, Duties and Requirements

Reference: [Reference: https://hbr.org/1994/03/managing-for-organizational-integrity, ]

A. Practicing data minimalism.

Answer DescriptionExplanation:
The important principle of Data Lifecycle Management (DLM) that will most likely be compromised if Anton executes his plan to limit data access to himself and Kenneth is ensuring data retrievability. Data retrievability refers to the ability to access and use data when needed for business purposes or legal obligations1 It involves maintaining the availability, integrity, and usability of data throughout its lifecycle2 However, if Anton restricts data access to only himself and Kenneth, he will create a single point of failure and a bottleneck for data retrieval. This could pose several risks and challenges for the company, such as:

• Losing data if Anton or Kenneth forgets the password or leaves the company without sharing it with others.
• Delaying data retrieval if Anton or Kenneth is unavailable or unresponsive when someone else needs the data urgently.
• Violating data protection laws or regulations that require data access by certain parties or authorities under certain circumstances.
• Reducing data quality or accuracy if Anton or Kenneth fails to update or maintain the data properly.
• Missing business opportunities or insights if Anton or Kenneth does not share the data with other relevant stakeholders or departments.

Therefore, Anton should reconsider his plan and adopt a more balanced and secure approach to data access management that follows the principle of least privilege. This means granting data access only to those who need it for their specific roles and responsibilities and revoking it when no longer needed3 He should also implement proper authentication, authorization, encryption, backup, and audit mechanisms to protect the data from unauthorized or unlawful access, use, disclosure, alteration, or destruction.

A. Interview the person reporting the incident following a standard protocol.

Answer DescriptionExplanation:
This answer is the best way to ascertain additional information about the loss of data, as it allows you to gather relevant facts and details from the person who witnessed or experienced the incident. A standard protocol for interviewing the person reporting the incident should include questions such as:
When and where did the incident occur?
What type and amount of data was involved?
How was the data stored or protected on the laptop?
Who else had access to or knowledge of the laptop or the data?
What actions have been taken so far to recover or secure the laptop or the data?
How did you discover or report the incident?
Do you have any evidence or clues about who may have taken or accessed the laptop or the data?
Do you have any other information that may be relevant or helpful for the investigation? Interviewing the person reporting the incident following a standard protocol can help you to establish a clear timeline and scope of the incident, identify potential sources of evidence, assess the level of risk and harm to the individuals and the organization, and determine the next steps for responding to and resolving the incident.