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Please use the following to answer the next question:

Richard McAdams recently graduated law school and decided to return to the small town of Lexington, Virginia

to help run his aging grandfather's law practice. The elder McAdams desired a limited, lighter role in the

practice, with the hope that his grandson would eventually take over when he fully retires. In addition to hiring

Richard, Mr. McAdams employs two paralegals, an administrative assistant, and a part-time IT specialist who

handles all of their basic networking needs. He plans to hire more employees once Richard gets settled and

assesses the office's strategies for growth.

Immediately upon arrival, Richard was amazed at the amount of work that needed to done in order to

modernize the office, mostly in regard to the handling of clients' personal data. His first goal is to digitize all the

records kept in file cabinets, as many of the documents contain personally identifiable financial and medical

data. Also, Richard has noticed the massive amount of copying by the administrative assistant throughout the

day, a practice that not only adds daily to the number of files in the file cabinets, but may create security issues

unless a formal policy is firmly in place Richard is also concerned with the overuse of the communal copier/

printer located in plain view of clients who frequent the building. Yet another area of concern is the use of the

same fax machine by all of the employees. Richard hopes to reduce its use dramatically in order to ensure that

personal data receives the utmost security and protection, and eventually move toward a strict Internet faxing

policy by the year's end.

Richard expressed his concerns to his grandfather, who agreed, that updating data storage, data security, and

an overall approach to increasing the protection of personal data in all facets is necessary Mr. McAdams

granted him the freedom and authority to do so. Now Richard is not only beginning a career as an attorney, but

also functioning as the privacy officer of the small firm. Richard plans to meet with the IT employee the following

day, to get insight into how the office computer system is currently set-up and managed.

Which of the following policy statements needs additional instructions in order to further protect the personal

data of their clients?

Please use the following to answer the next question:

You lead the privacy office for a company that handles information from individuals living in several countries

throughout Europe and the Americas. You begin that morning’s privacy review when a contracts officer sends

you a message asking for a phone call. The message lacks clarity and detail, but you presume that data was

lost.

When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating

that the vendor improperly shared information about your customers. He called the vendor and confirmed that

your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and

sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database

as promised in the contract. As a result, the vendor has lost control of the data.

The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell

you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the

mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write.

You put their offer on hold and begin to develop the text around the space constraints. You are content to let

the vendor’s logo be associated with the notification.

The notification explains that your company recently hired a vendor to store information about their most recent

experience at St. Sebastian Hospital’s Clinic for Infectious Diseases. The vendor did not encrypt the information

and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about

their information. They simply need to go to your company’s website and watch a quick advertisement, then

provide their name, email address, and month and year of birth.

You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation,

you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their

comments back and forth. The consultant who leads the incident-response team notes that it is his first day with

the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on

the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the

day, they vote to proceed with the notification you wrote and use the vendor’s postcards.

Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the

decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring

company with a convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled

a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:

1. Send an enrollment invitation to everyone the day after the contract is signed.

2. Enroll someone with just their first name and the last-4 of their national identifier.

3. Monitor each enrollee’s credit for two years from the date of enrollment.

4. Send a monthly email with their credit rating and offers for credit-related services at market rates.

5. Charge your company 20% of the cost of any credit restoration.

You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three days later

you sit down and document all that went well and all that could have gone better. You put it in a file to reference

the next time an incident occurs.

Regarding the credit monitoring, which of the following would be the greatest concern?

Please use the following to answer the next question:

Jonathan recently joined a healthcare payment processing solutions company as a senior privacy manager.

One morning, Jonathan awakens to several emails informing him that an individual cloud server failed due to a

flood in its server room, damaging its hardware and destroying all the data the company had stored on that

drive. Jonathan was not aware that the company had this particular cloud account or that any data was being

stored there because it was not included in the data mapping or data inventory provided to him by his

predecessor. Jonathan's predecessor conducted a data inventory and mapping exercise 4 years ago and

updated it on an annual basis.

Renee works in the sales department and tells Jonathan that she doesn't think that account had been used

since the company moved to a bigger cloud vendor three years ago. She also advised him that the account was

mostly used by Human Resources (HR) and Accounts Payable (AP). Jonathan speaks to both departments and

learns that each had met with his predecessor multiple times and explained they saved sensitive personal data

on that drive, including health and financial related personal data and "other stuff." Jonathan also learns that the

data stored in that account was not backed up pursuant to company policy. Jonathan asks his IT department

who had access to that particular account and learns that there were no access controls in place, making the

account available to anyone in the company, despite the purported sensitivity of the data being stored there.

Jonathan is panicking as the data can't be recovered, and he can't determine exactly what data was saved on

that account or to whom it belongs. Two days later, the company receives 32 data subject access requests and

Accounts Payable confirms Jonathan's worry that these data subjects' personal data was likely stored on this

account. He searches for the company's data subject access request policy, but later learns it doesn't exist.

Based on the scenario above, what is the most appropriate next step Jonathan should take?

Please use the following to answer the next question:

Manasa is a product manager at Omnipresent Omnimedia, where she is responsible for leading the

development of the company's flagship product, the Handy Helper. The Handy Helper is an application that can

be used in the home to manage family calendars, do online shopping, and schedule doctor appointments. After

having had a successful launch in the United States, the Handy Helper is about to be made available for

The packaging and user guide for the Handy Helper indicate that it is a "privacy friendly" product suitable for the

whole family, including children, but does not provide any further detail or privacy notice. In order to use the

application, a family creates a single account, and the primary user has access to all information about the

other users. Upon start up, the primary user must check a box consenting to receive marketing emails from

Omnipresent Omnimedia and selected marketing partners in order to be able to use the application.

Sanjay, the head of privacy at Omnipresent Omnimedia, was working on an agreement with a European

distributor of Handy Helper when he fielded many questions about the product from the distributor. Sanjay

needed to look more closely at the product in order to be able to answer the questions as he was not involved

in the product development process.

In speaking with the product team, he learned that the Handy Helper collected and stored all of a user's

sensitive medical information for the medical appointment scheduler. In fact, all of the user's information is

stored by Handy Helper for the additional purpose of creating additional products and to analyze usage of the

product. This data is all stored in the cloud and is encrypted both during transmission and at rest.

Consistent with the CEO's philosophy that great new product ideas can come from anyone, all Omnipresent

Omnimedia employees have access to user data under a program called Eureka. Omnipresent Omnimedia is

hoping that at some point in the future, the data will reveal insights that could be used to create a fully

automated application that runs on artificial intelligence, but as of yet, Eureka is not well-defined and is

considered a long-term goal.

What step in the system development process did Manasa skip?

Please use the following to answer the next question:

As they company’s new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically questionable practices, including unauthorized sales of personal data to marketers. Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company’s claims that “appropriate” data protection safeguards were in place. The scandal affected the company’s business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard’s mentor, was forced to step down.

Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company’s board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures. He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. “We want Medialite to have absolutely the highest standards,” he says. “In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company’s finances. So, while I want the best solutions across the board, they also need to be cost effective.”

You are told to report back in a week’s time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.

You give a presentation to your CEO about privacy program maturity. What does it mean to have a “managed” privacy program, according to the AICPA/CICA Privacy Maturity Model?

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