What is the most effective first step to take to operationalize Privacy by Design principles in new product development and projects?
SCENARIO
Kyle is a new security compliance manager who will be responsible for coordinating and executing controls to ensure compliance with the company's information security policy and industry standards. Kyle is also new to the company, where collaboration is a core value. On his first day of new-hire orientation, Kyle's schedule included participating in meetings and observing work in the IT and compliance departments.
Kyle spent the morning in the IT department, where the CIO welcomed him and explained that her department was responsible for IT governance. The CIO and Kyle engaged in a conversation about the importance of identifying meaningful IT governance metrics. Following their conversation, the CIO introduced Kyle to Ted and Barney. Ted is implementing a plan to encrypt data at the transportation level of the organization's wireless network. Kyle would need to get up to speed on the project and suggest ways to monitor effectiveness once the implementation was complete. Barney explained that his short-term goals are to establish rules governing where data can be placed and to minimize the use of offline data storage.
Kyle spent the afternoon with Jill, a compliance specialist, and learned that she was exploring an initiative for a compliance program to follow self-regulatory privacy principles. Thanks to a recent internship, Kyle had some experience in this area and knew where Jill could find some support. Jill also shared results of the company’s privacy risk assessment, noting that the secondary use of personal information was considered a high risk.
By the end of the day, Kyle was very excited about his new job and his new company. In fact, he learned about an open position for someone with strong qualifications and experience with access privileges, project standards board approval processes, and application-level obligations, and couldn’t wait to recommend his friend Ben who would be perfect for the job.
Ted's implementation is most likely a response to what incident?
Ivan is a nurse for a home healthcare service provider in the US. The company has implemented a mobile application which Ivan uses to record a patient's vital statistics and access a patient's health care records during home visits. During one visitj^van is unable to access the health care application to record the patient's vitals. He instead records the information on his mobile phone's note-taking application to enter the data in the health care application the next time it is accessible. What would be the best course of action by the IT department to ensure the data is protected on his device?
A Provide all healthcare employees with mandatory annual security awareness training with a focus on the health
information protection.
B. Complete a SWOT analysis exercise on the mobile application to identify what caused the application to be
inaccessible and remediate any issues.
C. Adopt mobile platform standards to ensure that only mobile devices that support encryption capabilities are used.
D. Implement Mobile Device Management (MDM) to enforce company security policies and configuration settings.
SCENARIO
Please use the following to answer the next question:
Jordan just joined a fitness-tracker start-up based in California, USA, as its first Information Privacy and Security Officer. The company is quickly growing its business but does not sell any of the fitness trackers itself. Instead, it relies on a distribution network of third-party retailers in all major countries. Despite not having any stores, the company has a 78% market share in the EU. It has a website presenting the company and products, and a member section where customers can access their information. Only the email address and physical address need to be provided as part of the registration process in order to customize the site to the user’s region and country. There is also a newsletter sent every month to all members featuring fitness tips, nutrition advice, product spotlights from partner companies based on user behavior and preferences.
Jordan says the General Data Protection Regulation (GDPR) does not apply to the company. He says the company is not established in the EU, nor does it have a processor in the region. Furthermore, it does not do any “offering goods or services” in the EU since it does not do any marketing there, nor sell to consumers directly. Jordan argues that it is the customers who chose to buy the products on their own initiative and there is no “offering” from the company.
The fitness trackers incorporate advanced features such as sleep tracking, GPS tracking, heart rate monitoring. wireless syncing, calorie-counting and step-tracking. The watch must be paired with either a smartphone or a computer in order to collect data on sleep levels, heart rates, etc. All information from the device must be sent to the company’s servers in order to be processed, and then the results are sent to the smartphone or computer. Jordan argues that there is no personal information involved since the company does not collect banking or social security information.
Based on the current features of the fitness watch, what would you recommend be implemented into each device in order to most effectively ensure privacy?
SCENARIO
WebTracker Limited is a cloud-based online marketing service located in London. Last year, WebTracker migrated its IT infrastructure to the cloud provider AmaZure, which provides SQL Databases and Artificial Intelligence services to WebTracker. The roles and responsibilities between the two companies have been formalized in a standard contract, which includes allocating the role of data controller to WebTracker.
The CEO of WebTracker, Mr. Bond, would like to assess the effectiveness of AmaZure's privacy controls, and he recently decided to hire you as an independent auditor. The scope of the engagement is limited only to the marketing services provided by WebTracker, you will not be evaluating any internal data processing activity, such as HR or Payroll.
This ad-hoc audit was triggered due to a future partnership between WebTracker and SmartHome — a partnership that will not require any data sharing. SmartHome is based in the USA, and most recently has dedicated substantial resources to developing smart refrigerators that can suggest the recommended daily calorie intake based on DNA information. This and other personal data is collected by WebTracker.
To get an idea of the scope of work involved, you have decided to start reviewing the company's documentation and interviewing key staff to understand potential privacy risks.
The results of this initial work include the following notes:
Which of the following issues is most likely to require an investigation by the Chief Privacy Officer (CPO) of WebTracker?
Which of the following is NOT relevant to a user exercising their data portability rights?
SCENARIO
Please use the following to answer next question:
EnsureClaim is developing a mobile app platform for managing data used for assessing car accident insurance claims. Individuals use the app to take pictures at the crash site, eliminating the need for a built-in vehicle camera. EnsureClaim uses a third-party hosting provider to store data collected by the app. EnsureClaim customer service employees also receive and review app data before sharing with insurance claim adjusters.
The app collects the following information:
First and last name
Date of birth (DOB)
Mailing address
Email address
Car VIN number
Car model
License plate
Insurance card number
Photo
Vehicle diagnostics
Geolocation
All of the following technical measures can be implemented by EnsureClaim to protect personal information that is accessible by third-parties EXCEPT?
Which of these actions is NOT generally part of the responsibility of an IT or software engineer?
SCENARIO
Please use the following to answer the next questions:
Your company is launching a new track and trace health app during the outbreak of a virus pandemic in the US. The developers claim the app is based on privacy by design because personal data collected was considered to ensure only necessary data is captured, users are presented with a privacy notice, and they are asked to give consent before data is shared. Users can update their consent after logging into an account, through a dedicated privacy and consent hub. This is accessible through the 'Settings' icon from any app page, then clicking 'My Preferences', and selecting 'Information Sharing and Consent' where the following choices are displayed:
• "I consent to receive notifications and infection alerts";
• "I consent to receive information on additional features or services, and new products";
• "I consent to sharing only my risk result and location information, for exposure and contact tracing purposes";
• "I consent to share my data for medical research purposes"; and
• "I consent to share my data with healthcare providers affiliated to the company".
For each choice, an ON* or OFF tab is available The default setting is ON for all
Users purchase a virus screening service for USS29 99 for themselves or others using the app The virus screening
service works as follows:
• Step 1 A photo of the user's face is taken.
• Step 2 The user measures their temperature and adds the reading in the app
• Step 3 The user is asked to read sentences so that a voice analysis can detect symptoms
• Step 4 The user is asked to answer questions on known symptoms
• Step 5 The user can input information on family members (name date of birth, citizenship, home address, phone number, email and relationship).)
The results are displayed as one of the following risk status "Low. "Medium" or "High" if the user is deemed at "Medium " or "High" risk an alert may be sent to other users and the user is Invited to seek a medical consultation and diagnostic from a healthcare provider.
A user’s risk status also feeds a world map for contact tracing purposes, where users are able to check if they have been or are in dose proximity of an infected person If a user has come in contact with another individual classified as "medium’ or 'high' risk an instant notification also alerts the user of this. The app collects location trails of every user to monitor locations visited by an infected individual Location is collected using the phone's GPS functionary, whether the app is in use or not however, the exact location of the user is "blurred' for privacy reasons Users can only see on the map circles
What is likely to be the biggest privacy concern with the current 'Information Sharing and Consent' page?
Information classification helps an organization protect confidential and nonpublic information primarily because?
To meet data protection and privacy legal requirements that may require personal data to be disposed of or deleted when no longer necessary for the use it was collected, what is the best privacy-enhancing solution a privacy technologist should recommend be implemented in application design to meet this requirement?
Which of the following methods does NOT contribute to keeping the data confidential?
Which Organization for Economic Co-operation and Development (OECD) privacy protection principle encourages an organization to obtain an individual s consent before transferring personal information?
When designing a new system, which of the following is a privacy threat that the privacy technologist should consider?
SCENARIO
Carol was a U.S.-based glassmaker who sold her work at art festivals. She kept things simple by only accepting cash and personal checks.
As business grew, Carol couldn't keep up with demand, and traveling to festivals became burdensome. Carol opened a small boutique and hired Sam to run it while she worked in the studio. Sam was a natural salesperson, and business doubled. Carol told Sam, “I don't know what you are doing, but keep doing it!"
But months later, the gift shop was in chaos. Carol realized that Sam needed help so she hired Jane, who had business expertise and could handle the back-office tasks. Sam would continue to focus on sales. Carol gave Jane a few weeks to get acquainted with the artisan craft business, and then scheduled a meeting for the three of them to discuss Jane's first impressions.
At the meeting, Carol could not wait to hear Jane's thoughts, but she was unprepared for what Jane had to say. “Carol, I know that he doesn't realize it, but some of Sam’s efforts to increase sales have put you in a vulnerable position. You are not protecting customers’ personal information like you should.”
Sam said, “I am protecting our information. I keep it in the safe with our bank deposit. It's only a list of customers’ names, addresses and phone numbers that I get from their checks before I deposit them. I contact them when you finish a piece that I think they would like. That's the only information I have! The only other thing I do is post photos and information about your work on the photo sharing site that I use with family and friends. I provide my email address and people send me their information if they want to see more of your work. Posting online really helps sales, Carol. In fact, the only complaint I hear is about having to come into the shop to make a purchase.”
Carol replied, “Jane, that doesn’t sound so bad. Could you just fix things and help us to post even more online?"
‘I can," said Jane. “But it's not quite that simple. I need to set up a new program to make sure that we follow the best practices in data management. And I am concerned for our customers. They should be able to manage how we use their personal information. We also should develop a social media strategy.”
Sam and Jane worked hard during the following year. One of the decisions they made was to contract with an outside vendor to manage online sales. At the end of the year, Carol shared some exciting news. “Sam and Jane, you have done such a great job that one of the biggest names in the glass business wants to buy us out! And Jane, they want to talk to you about merging all of our customer and vendor information with theirs beforehand."
Which regulator has jurisdiction over the shop's data management practices?
Not updating software for a system that processes human resources data with the latest security patches may create what?
Aadhaar is a unique-identity number of 12 digits issued to all Indian residents based on their biometric and demographic data. The data is collected by the Unique Identification Authority of India. The Aadhaar database contains the Aadhaar number, name, date of birth, gender and address of over 1 billion individuals.
Which of the following datasets derived from that data would be considered the most de-identified?
What is the goal of privacy enhancing technologies (PETS) like multiparty computation and differential privacy?
SCENARIO
Please use the following to answer the next question:
Light Blue Health (LBH) is a healthcare technology company developing a new web and mobile application that collects personal health information from electronic patient health records. The application will use machine learning to recommend potential medical treatments and medications based on information collected from anonymized electronic health records. Patient users may also share health data collected from other mobile apps with the LBH app.
The application requires consent from the patient before importing electronic health records into the application and sharing it with their authorized physicians or healthcare provider. The patient can then review and share the recommended treatments with their physicians securely through the app. The patient user may also share location data and upload photos in the app. The patient user may also share location data and upload photos in the app for a healthcare provider to review along with the health record. The patient may also delegate access to the app.
LBH’s privacy team meets with the Application development and Security teams, as well as key business stakeholders on a periodic basis. LBH also implements Privacy by Design (PbD) into the application development process.
The Privacy Team is conducting a Privacy Impact Assessment (PIA) to evaluate privacy risks during development of the application. The team must assess whether the application is collecting descriptive, demographic or any other user related data from the electronic health records that are not needed for the purposes of the application. The team is also reviewing whether the application may collect additional personal data for purposes for which the user did not provide consent.
The Privacy Team is conducting a Privacy Impact Assessment (PIA) for the new Light Blue Health application currently in development. Which of the following best describes a risk that is likely to result in a privacy breach?
SCENARIO
Please use the following to answer next question:
EnsureClaim is developing a mobile app platform for managing data used for assessing car accident insurance claims. Individuals use the app to take pictures at the crash site, eliminating the need for a built-in vehicle camera. EnsureClaim uses a third-party hosting provider to store data collected by the app. EnsureClaim customer service employees also receive and review app data before sharing with insurance claim adjusters.
The app collects the following information:
First and last name
Date of birth (DOB)
Mailing address
Email address
Car VIN number
Car model
License plate
Insurance card number
Photo
Vehicle diagnostics
Geolocation
What would be the best way to supervise the third-party systems the EnsureClaim App will share data with?
SCENARIO
Please use the following to answer the next question:
Chuck, a compliance auditor for a consulting firm focusing on healthcare clients, was required to travel to the client’s office to perform an onsite review of the client’s operations. He rented a car from Finley Motors upon arrival at the airport as so he could commute to and from the client’s office. The car rental agreement was electronically signed by Chuck and included his name, address, driver’s license, make/model of the car, billing rate, and additional details describing the rental transaction. On the second night, Chuck was caught by a red light camera not stopping at an intersection on his way to dinner. Chuck returned the car back to the car rental agency at the end week without mentioning the infraction and Finley Motors emailed a copy of the final receipt to the address on file.
Local law enforcement later reviewed the red light camera footage. As Finley Motors is the registered owner of the car, a notice was sent to them indicating the infraction and fine incurred. This notice included the license plate number, occurrence date and time, a photograph of the driver, and a web portal link to a video clip of the violation for further review. Finley Motors, however, was not responsible for the violation as they were not driving the car at the time and transferred the incident to AMP Payment Resources for further review. AMP Payment Resources identified Chuck as the driver based on the rental agreement he signed when picking up the car and then contacted Chuck directly through a written letter regarding the infraction to collect the fine.
After reviewing the incident through the AMP Payment Resources’ web portal, Chuck paid the fine using his personal credit card. Two weeks later, Finley Motors sent Chuck an email promotion offering 10% off a future rental.
What is the strongest method for authenticating Chuck’s identity prior to allowing access to his violation information through the AMP Payment Resources web portal?
Which privacy engineering objective proposed by the US National Institute of Science and Technology (NIST) decreases privacy risk by ensuring that connections between individuals and their personal data are reduced?
A computer user navigates to a page on the Internet. The privacy notice pops up and the user clicks the box to accept cookies, then continues to scroll the page to read the Information displayed. This is an example of which type of consent?