How are privacy and data protection related to each other?

A. Data protection is a subset of privacy.

B. Privacy is a subset of data protection.

C. The terms `privacy' and `data protection' are interchangeable.

D. They are unrelated.

Certification once granted, will be valid for period of _______ years subject to surveillance assessments.

A. 4

B. 5

C. 3

D. 1

Classify the following scenario as major or minor non-conformity.

"The organization has a very mature information security policy. Lately, the organization has realized the need to focus on protection of PI. A formal PI identification exercise was done for this purpose and a mapping of PI and security controls was done. The organization has also put in place data masking technology in certain functions where the SPI was accessed by employees of a third party. However, the organization is yet to include PI specifically in its risk assessment exercise, incident management, testing, data classification and security architecture programs."

A. Major

B. Minor

C. Both Major and Minor

D. None of the above

Which of the following is not in line with the modem definition of Consent?

A. Consent is taken by clear and affirmative action

B. Consenting individual should have the ability to withdraw consent

C. Consent should be bundled in nature

D. Purpose of processing should be informed to the individual before consenting

______________ is used to identify and reduce privacy risks by analyzing what is processed by the entity and the policies in place to protect the data.

A. Privacy Impact Assessment

B. Anonymization

C. Threat Hunting

D. Minimization

__________ calls for inclusion of data protection from the onset of the designing of systems.

A. Agile Model

B. Privacy by Design

C. Logical Design

D. Safeguarding Approach

As a privacy assessor, what would most likely be the first artefact you would ask for while assessing an organization which claims that it has implemented a privacy program?

A. Privacy risk management framework

B. Records of privacy specific training imparted to the employees handling personal information

C. Personal information management policy

D. Records of deployed privacy notices and statements

Which of the following provisions of Information Technology (Amendment) Act, 2008 deal with protection of PI or SPDI of Individuals?

A. Section 43A and Section 72A

B. Section 43A

C. Section 65

D. Section 43A and Section 65

IUA and PAT

The company has a very mature enterprise level access control policy to restrict access to information. There is a single sign-on platform available to access company resources such as email, intranet, servers, etc. However, the access policy in client relationships varies depending on the client requirements. In fact, in many cases clients provide access ids to the employees of the company and manage them. Some clients also put technical controls to limit access to information such data masking tool, encryption, and anonymizing data, among others. Some clients also record the data collection process to monitor if the employee of the company does not collect more data than is required. Taking cue from the best practices implemented by the clients, the company, through the consultants, thought of realigning its access control policy to include control on data collection and data usage by the business functions and associated third parties. As a first step, the consultants advised the company to start monitoring the PI collection, usage and access by business functions without their knowledge. The IT function was given the responsibility to do the monitoring, as majority of the information was handled electronically. The analysis showed that many times, more information than necessary was collected by the some functions, however, no instances of misuse could be identified. After few days of this exercise, a complaint was registered by a female company employee in the HR function against a male employee in IT support function. The female employee accused the male employee of accessing her photographs stored on a shared drive and posting it on a social networking site.

(Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion)

Introduction and Background XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than 500 clients across industry verticals -- BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.

The company is witnessing phenomenal growth in the BPM services over last few years including Finance and Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects. The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).

To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens. The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.

Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.

What should the company do to limit data collection and usage and at the same time ensure that such kinds of incidents don't reoccur? (250 to 500 words)

A. See the answer in explanation below.

B. PlaceHolder

C. PlaceHolder

D. PlaceHolder

Privacy enhancing tools aim to allow users to take one or more of the following actions related to their personal data that is sent to, and used by online service providers, merchants or other users:

I) Increase control over their personal data

II) Choose whether to use services anonymously or not

III) Obtain informed consent about sharing their personal data

IV) Opt-out of behavioral advertising or any other use of data

A. Only I

B. Only I and II

C. I, II, III and IV

D. Only II