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| Section | Weight | Objectives |
|---|---|---|
| Privacy Architecture and Technical Controls | 15-20% | - Access Controls and Authentication - Encryption and Security Technologies - Data Anonymization and Pseudonymization - Data Lifecycle Management |
| Privacy Laws and Regulations | 15-20% | - Sector-specific Privacy Requirements - Cross-border Data Transfer Regulations - GDPR Compliance - Indian Privacy Laws (IT Act, DPDP Bill) |
| Privacy Assessment Methodology | 15-20% | - Assessment Frameworks and Standards - Reporting and Remediation Guidance - Audit and Review Techniques - Evidence Collection and Documentation |
| Emerging Technologies and Privacy | 5-10% | - Cloud Computing Privacy - AI/ML Privacy Considerations - IoT and Big Data Privacy |
| Privacy Risk Assessment and Management | 20-25% | - Data Protection Impact Assessment (DPIA) - Privacy Impact Assessment (PIA) - Risk Identification and Mitigation - Threat Modeling for Privacy |
| Privacy Framework and Governance | 20-25% | - Privacy Governance Frameworks - Privacy Principles and Concepts - Regulatory Compliance (GDPR, IT Act, etc.) - Privacy by Design and Default |
1. Classify the following scenario as major or minor non-conformity
"An India based organization is expanding operations in Europe To deliver its services, it needs to deal with PI of its customers The organization is not fully aware of how the data protection legislations in EU Member States will affect its operations what will be its liabilities and how it needs to address those. The legal learn was given the responsibility to understand the issues and come out with detailed plan. The legal function did not have any m-house expert in privacy or international law The legal team assigned a senior resource on the job This person used the resources available on the internet to understand the legal privacy issues in EU and based on her research recommended the action plan, which was accepted by the management"
A) Major
B) Both Major & Minor
C) Minor
D) None of the above
2. With respect to privacy monitoring and incident management process, which of the following should be a part of a standard incident handling process?
I) Incident identification and notification
II) Investigation and remediation
III) Root cause analysis
IV) User awareness training on how to report incidents
A) III and IV
B) I, II and III
C) All of the Above
D) I and II
3. From the following list, identify the technology aspects that are specially designed for upholding privacy:
I) Data minimization
II) Intrusion prevention system
III) Data scrambling
IV) Data loss prevention
V) Data portability
VI) Data obfuscation
VII) Data encryption
VIII) Data mirroring
A) Only I, II, III, VII and VIII
B) Only I, III, IV, VI and VII
C) Only II, V, VI, VII and VIII
D) Only I, III, V, VII and VIII
4. FILL BLANK
MIM
The company has a well-defined and tested Information security monitoring and incident management process in place. The process has been in place since last 10 years and has matured significantly over a period of time. There is a Security Operations Centre (SOC) to detect security incidents based on well-defined business rules.
The security incident management is based on ISO 27001 and defines incident types, alert levels, roles and responsibilities, escalation matrix, among others. The consultants advised company to realign the existing monitoring and incident management to cater to privacy requirements. The company consultants sought help of external privacy expert in this regard.
(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.
If you were the privacy expert advising the company, what steps would you suggest to realign the existing security monitoring and incident management to address privacy requirements especially those specific to client relationships? (250 to 500 words)
5. There are several privacy incidents reported in an organization. The organization plans to analyze and learn from these incidents. Which privacy practice will the organization have to implement for the same?
A) Privacy monitoring and incident management
B) Privacy awareness and training
C) Privacy contract management
D) Information usage and access
Solutions:
| Question # 1 Answer: A | Question # 2 Answer: C | Question # 3 Answer: B | Question # 4 Answer: Only visible for members | Question # 5 Answer: A |
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