CDPSE Exam Dumps - Isaca Certification Questions and Answers

The data controller determines the purposes and means of processing and therefore retains primary accountability for risk—even if a processor or custodian executes processing. Data processors (C) act under instructions; custodians (A) safeguard data but do not define processing; data scientists (B) are operational users, not accountable owners.

“The data controller remains accountable for compliance and risk regardless of outsourcing processing activities.”

A current and accurate data map enables organizations to locate personal data across systems, which is essential for responding to access, rectification, erasure, and portability requests. DLP (A) prevents leakage, not rights fulfillment; breach handling (B) addresses incidents, not rights; contact forms (C) provide intake but not fulfillment.

“Data maps provide visibility into where and how personal data is processed, enabling rights fulfillment.”

The applicable privacy legislation needs to be identified first to define the privacy requirements to use when assessing the selection of IT systems, because it sets the legal obligations and standards for the organization to comply with when processing personal data. The type of data, the control frameworks, and the technology platforms are all dependent on the privacy legislation that applies to the organization and its data processing activities. Therefore, the privacy legislation is the primary source of privacy requirements for IT systems.

The best approach for handling personal data that has been restricted is to flag users’ email addresses to make sure they do not receive promotional information, because this will respect the users’ preferences and rights to opt out of marketing communications. This will also help the company comply with the data protection laws and regulations that require consent and transparency for sending marketing emails, such as the General Data Protection Regulation (GDPR) and the CAN-SPAM Act12. The other options are not appropriate or sufficient for handling restricted data, because they may violate the users’ rights, expectations, or agreements, or cause operational issues for the company.

The most important consideration when writing an organization’s privacy policy is to align the statements to the organizational practices, because this will help ensure that the policy is accurate, consistent, and transparent. A privacy policy is a document that explains how the organization collects, uses, discloses, and protects personal data from its customers, employees, partners, and other stakeholders. A privacy policy should reflect the actual data processing activities and privacy measures of the organization, as well as comply with the applicable laws and regulations. A privacy policy that is not aligned with the organizational practices may lead to confusion, mistrust, or legal liability12.

However, the risks associated with long-term retention have compelled organizations to consider alternatives; one is data archival, the process of preparing data for long-term storage. When organizations are bound by specific laws to retain data for many years, archival provides a viable opportunity to remove data from online transaction systems to other systems or media.

Data archiving is the process of moving data that is no longer actively used to a separate storage device for long-term retention. Data archiving helps to reduce the cost and complexity of data storage, improve the performance and availability of data systems, and comply with data retention policies and regulations. Data archiving should document controls relating to periods of retention for personal data, such as the criteria for determining the retention period, the procedures for deleting or anonymizing data after the retention period expires, and the mechanisms for ensuring the integrity and security of archived data. References: : CDPSE Review Manual (Digital Version), page 123

The primary means by which an organization communicates customer rights as it relates to the use of their personal information is publishing a privacy notice. A privacy notice is a document that informs the customers about how the organization collects, uses, shares, and protects their personal information, and what rights and choices they have regarding their data4. A privacy notice is a legal requirement under many data protection laws and regulations, such as the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), or the Personal Information Protection and Electronic Documents Act (PIPEDA)5 . A privacy notice is also a good practice to demonstrate the organization’s commitment to transparency, accountability, and customer trust. References:

ISACA Glossary of Terms

Article 13 and 14 of the GDPR

[Section 1798.100 of the CCPA]

[Schedule 1, Principle 4.8 of the PIPEDA]

[ISACA CDPSE Review Manual, Chapter 1, Section 1.3.2]

Senior leadership must define the roles and responsibilities of the person with oversight, who is responsible for ensuring compliance with the data privacy policy and applicable laws and regulations. This person may also be known as the data protection officer, the privacy officer, or the chief privacy officer, depending on the organization and jurisdiction. The person with oversight should have the authority, resources, and independence to perform their duties effectively.

Implementing multi-factor authentication is the best way to reduce the risk of compromised credentials when an organization allows employees to have remote access, as it adds an extra layer of security and verification to the authentication process. Multi-factor authentication requires the user to provide two or more pieces of evidence to prove their identity, such as something they know (e.g., password, PIN), something they have (e.g., token, smart card), or something they are (e.g., fingerprint, face scan)135. References: 1 Domain 2, Task 8;

The principle of least privilege is the most important principle to apply when granting access to an ERP system that contains a significant amount of personal data. The principle of least privilege states that users should only have the minimum level of access and permissions necessary to perform their legitimate tasks and functions, and no more. Applying the principle of least privilege helps to protect the privacy and security of the personal data in the ERP system, as it reduces the risk of unauthorized or inappropriate access, disclosure, modification, or deletion of the data. It also helps to comply with the privacy laws and regulations, such as the GDPR, that require data controllers and processors to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.