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CIPP-US Test Preparation: Certified Information Privacy Professional/United States (CIPP/US) & CIPP-US Exam Lab Questions
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IAPP CIPP-US certification exam covers various topics, including privacy program governance, risk management, and incident management. It tests proficiency in applying privacy laws to the collection, use, retention, and disclosure of personal information. Privacy professionals who hold the CIPP/US certification are well-equipped to handle the increasing demand for privacy compliance in the digital age. Attaining this certification showcases a commitment to the privacy field and sets the individual apart as a subject matter expert in the industry.
The CIPP/US exam covers several areas of privacy law, including the U.S. privacy legal framework, privacy program governance, data protection, and privacy compliance. CIPP-US Exam consists of 90 multiple-choice questions, and test-takers have up to two and a half hours to complete it. Passing the exam requires a score of 300 or higher out of a possible 500 points.
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IAPP Certified Information Privacy Professional/United States (CIPP/US) Sample Questions (Q178-Q183):
NEW QUESTION # 178
Under the Fair and Accurate Credit Transactions Act (FACTA), what is the most appropriate action for a car dealer holding a paper folder of customer credit reports?
- A. To follow the Privacy Rule by notifying customers that the reports are being stored
- B. To follow the Red Flags Rule by mailing the reports to customers
- C. To follow the Safeguards Rule by transferring the reports to a secure electronic file
- D. To follow the Disposal Rule by having the reports shredded
Answer: D
Explanation:
The Disposal Rule is a provision of the Fair and Accurate Credit Transactions Act (FACTA) that requires businesses and individuals to take appropriate measures to dispose of sensitive information about consumers, such as credit reports, that are derived from consumer reports. The Disposal Rule is intended to reduce the risk of identity theft and fraud by preventing unauthorized access to or use of the information. According to the Disposal Rule, reasonable steps for disposal include burning, pulverizing, or shredding papers that contain consumer report information so that they cannot be read or reconstructed.
In this scenario, the most appropriate action for a car dealer holding a paper folder of customer credit reports is to follow the Disposal Rule by having the reports shredded. This would ensure that the car dealer complies with the FACTA and protects the privacy and security of the customers' personal data. The other options are not correct, because:
* The Red Flags Rule is another provision of the FACTA that requires financial institutions and creditors to implement a written identity theft prevention program that identifies and responds to the warning signs or red flags of identity theft in their operations. The Red Flags Rule does not apply to the disposal of consumer report information, nor does it require mailing the reports to customers, which could expose the information to interception or theft.
* The Privacy Rule is a provision of the Gramm-Leach-Bliley Act (GLBA) that requires financial institutions to provide notice to customers about their privacy policies and practices, and to allow customers to opt out of sharing their personal information with certain third parties. The Privacy Rule does not apply to the disposal of consumer report information, nor does it require notifying customers that the reports are being stored, which could alert potential identity thieves to the existence of the information.
* The Safeguards Rule is another provision of the GLBA that requires financial institutions to develop, implement, and maintain a comprehensive information security program that protects the security, confidentiality, and integrity of customer information. The Safeguards Rule does not apply to the disposal of consumer report information, nor does it require transferring the reports to a secure electronic file, which could still be vulnerable to hacking or unauthorized access.
References:
* FTC website, FACTA Disposal Rule Goes into Effect June 1
* Shred Nations website, What Is the FACTA Disposal Rule?
* Seam Services website, The FACTA Disposal Rule: What Does It Mean for Your Business?
* IAPP CIPP/US Study Guide, Chapter 2: Limits on Private-sector Collection and Use of Data, pp. 49-50
* IAPP website, Red Flags Rule
* IAPP website, Fair and Accurate Credit Transactions Act (FACTA)
NEW QUESTION # 179
SCENARIO -
Please use the following to answer the next question:
Miraculous Healthcare is a large medical practice with multiple locations in California and Nevad a. Miraculous normally treats patients in person, but has recently decided to start offering telehealth appointments, where patients can have virtual appointments with on-site doctors via a phone app.
For this new initiative, Miraculous is considering a product built by MedApps, a company that makes quality telehealth apps for healthcare practices and licenses them to be used with the practices' branding. MedApps provides technical support for the app, which it hosts in the cloud. MedApps also offers an optional benchmarking service for providers who wish to compare their practice to others using the service.
Riya is the Privacy Officer at Miraculous, responsible for the practice's compliance with HIPAA and other applicable laws, and she works with the Miraculous procurement team to get vendor agreements in place. She occasionally assists procurement in vetting vendors and inquiring about their own compliance practices, as well as negotiating the terms of vendor agreements. Riya is currently reviewing the suitability of the MedApps app from a privacy perspective.
Riya has also been asked by the Miraculous Healthcare business operations team to review the MedApps' optional benchmarking service. Of particular concern is the requirement that Miraculous Healthcare upload information about the appointments to a portal hosted by MedApps.
What HIPAA compliance issue would Miraculous have to consider before using the telehealth app?
- A. HIPAA does not permit in-person appointment data to be hosted in the cloud.
- B. HIPAA would require Miraculous and MedApps to enter into a Business Associate Agreement.
- C. HIPAA does not permit healthcare providers to use cloud hosting services.
- D. HIPAA would require Miraculous to obtain patient consent before in-person appointment data can be shared with third parties.
Answer: B
NEW QUESTION # 180
A covered entity suffers a ransomware attack that affects the personal health information (PHI) of more than 500 individuals. According to Federal law under HIPAA, which of the following would the covered entity NOT have to report the breach to?
- A. The local media
- B. The affected individuals
- C. Medical providers
- D. Department of Health and Human Services
Answer: C
NEW QUESTION # 181
SCENARIO
Please use the following to answer the next QUESTION:
Cheryl is the sole owner of Fitness Coach, Inc., a medium-sized company that helps individuals realize their physical fitness goals through classes, individual instruction, and access to an extensive indoor gym. She has owned the company for ten years and has always been concerned about protecting customer's privacy while maintaining the highest level of service. She is proud that she has built long-lasting customer relationships.
Although Cheryl and her staff have tried to make privacy protection a priority, the company has no formal privacy policy. So Cheryl hired Janice, a privacy professional, to help her develop one.
After an initial assessment, Janice created a first of a new policy. Cheryl read through the draft and was concerned about the many changes the policy would bring throughout the company. For example, the draft policy stipulates that a customer's personal information can only be held for one year after paying for a service such as a session with personal trainer. It also promises that customer information will not be shared with third parties without the written consent of the customer. The wording of these rules worry Cheryl since stored personal information often helps her company to serve her customers, even if there are long pauses between their visits. In addition, there are some third parties that provide crucial services, such as aerobics instructors who teach classes on a contract basis. Having access to customer files and understanding the fitness levels of their students helps instructors to organize their classes.
Janice understood Cheryl's concerns and was already formulating some ideas for revision. She tried to put Cheryl at ease by pointing out that customer data can still be kept, but that it should be classified according to levels of sensitivity. However, Cheryl was skeptical. It seemed that classifying data and treating each type differently would cause undue difficulties in the company's day-to-day operations. Cheryl wants one simple data storage and access system that any employee can access if needed.
Even though the privacy policy was only a draft, she was beginning to see that changes within her company were going to be necessary. She told Janice that she would be more comfortable with implementing the new policy gradually over a period of several months, one department at a time. She was also interested in a layered approach by creating documents listing applicable parts of the new policy for each department.
What is the most likely risk of Fitness Coach, Inc. adopting Janice's first draft of the privacy policy?
- A. Showing a lack of trust in the organization's privacy practices
- B. Not being in standard compliance with applicable laws
- C. Leaving the company susceptible to violations by setting unrealistic goals
- D. Failing to meet the needs of customers who are concerned about privacy
Answer: C
NEW QUESTION # 182
SCENARIO
Please use the following to answer the next QUESTION
Otto is preparing a report to his Board of Directors at Filtration Station, where he is responsible for the privacy program. Filtration Station is a U.S. company that sells filters and tubing products to pharmaceutical companies for research use. The company is based in Seattle, Washington, with offices throughout the U.S.
and Asia. It sells to business customers across both the U.S. and the Asia-Pacific region. Filtration Station participates in the Cross-Border Privacy Rules system of the APEC Privacy Framework.
Unfortunately, Filtration Station suffered a data breach in the previous quarter. An unknown third party was able to gain access to Filtration Station's network and was able to steal data relating to employees in the company's Human Resources database, which is hosted by a third-party cloud provider based in the U.S. The HR data is encrypted. Filtration Station also uses the third-party cloud provider to host its business marketing contact database. The marketing database was not affected by the data breach. It appears that the data breach was caused when a system administrator at the cloud provider stored the encryption keys with the data itself.
The Board has asked Otto to provide information about the data breach and how updates on new developments in privacy laws and regulations apply to Filtration Station. They are particularly concerned about staying up to date on the various U.S. state laws and regulations that have been in the news, especially the California Consumer Privacy Act (CCPA) and breach notification requirements.
What can Otto do to most effectively minimize the privacy risks involved in using a cloud provider for the HR data?
- A. Request that the Board sign off in a written document on the choice of cloud provider.
- B. Ensure that the cloud provider abides by the contractual requirements by conducting an on-site audit.
- C. Negotiate a Business Associate Agreement with the cloud provider to protect any health-related data employees might share with Filtration Station.
- D. Obtain express consent from employees for storing the HR data in the cloud and keep a record of the employee consents.
Answer: B
Explanation:
The best way for Otto to minimize the privacy risks involved in using a cloud provider for the HR data is to ensure that the cloud provider abides by the contractual requirements by conducting an on-site audit. This would allow Otto to verify that the cloud provider has implemented adequate security measures, such as encryption, access controls, and backup systems, to protect the HR data from unauthorized access, use, or disclosure. It would also allow Otto to check that the cloud provider is complying with the applicable privacy laws and regulations, such as the CCPA, the APEC Privacy Framework, and the breach notification requirements. By conducting an on-site audit, Otto can identify any gaps or weaknesses in the cloud provider's privacy practices and address them promptly. This would also demonstrate due diligence and accountability on the part of Filtration Station, which could mitigate the legal and reputational consequences of a data breach. References:
* [IAPP CIPP/US Study Guide], Chapter 3: Data Assessments, pp. 77-78.
* IAPP CIPP/US Body of Knowledge, Section III: Government and Court Access to Private-sector Information, Subsection B: Cross-Border Data Transfer, Topic 2: APEC Privacy Framework.
* IAPP CIPP/US Practice Questions, Question 125.
NEW QUESTION # 183
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