IAPP CIPM Exam Questions

Types of privacy program metrics include business enablement metrics, data enhancement metrics, and commercial metrics. Business enablement metrics measure the effectiveness of the privacy program in enabling the business to function without compromising privacy. Data enhancement metrics measure the effectiveness of the privacy program in enhancing data protection, such as through data minimization, access controls, and data security. Commercial metrics measure the effectiveness of the privacy program in creating value, such as through the development of new products, services, and customer experiences.

Privacy program metrics are used to assess the effectiveness of a privacy program and measure its progress. These metrics can include business enablement metrics, data enhancement metrics, and commercial metrics. Value creation metrics, however, are not typically used as privacy program metrics.

The optimum first step to take when creating a Privacy Officer governance model is to involve senior leadership. Senior leadership plays a crucial role in establishing and supporting a privacy program within an organization. They can provide strategic direction, allocate resources, approve policies, endorse initiatives, communicate values, and demonstrate accountability. By involving senior leadership from the beginning, a Privacy Officer can ensure that the privacy program aligns with the organization's vision, mission, goals, and culture. Senior leadership can also help overcome potential barriers or resistance from other stakeholders by endorsing and promoting the privacy program.

CIPM Body of Knowledge (2021), Domain I: Privacy Program Governance, Section A: Privacy Governance Models, Subsection 1: Privacy Officer Governance Model

CIPM Study Guide (2021), Chapter 2: Privacy Governance Models, Section 2.1: Privacy Officer Governance Model

CIPM Textbook (2019), Chapter 2: Privacy Governance Models, Section 2.1: Privacy Officer Governance Model

CIPM Practice Exam (2021), Question 139

Under the General Data Protection Regulation (GDPR), the obligations of a processor that engages a sub-processor are to obtain the consent of the controller and ensure the sub-processor complies with data processing obligations that are equivalent to those that apply to the processor. The GDPR defines a processor as a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller. A sub-processor is a third party that is engaged by the processor to carry out specific processing activities on behalf of the controller. The GDPR requires that the processor does not engage another processor without prior specific or general written authorization of the controller. In the case of general written authorization, the processor must inform the controller of any intended changes concerning the addition or replacement of other processors, thereby giving the controller the opportunity to object to such changes. The processor must also ensure that the same data protection obligations as set out in the contract or other legal act between the controller and the processor are imposed on that other processor by way of a contract or other legal act under Union or Member State law, .Reference:[GDPR Article 28], [CIPM - International Association of Privacy Professionals]

Crafting policies which ensure minimal data is collected is least likely to be achieved by implementing a Data Lifecycle Management (DLM) program, as it is more related to the data collection stage, not the data management stage. A DLM program focuses on how to handle the data after it has been collected, such as how to store, use, share, and dispose of it. The other options are more likely to be achieved by implementing a DLM program, as they help to optimize the data storage costs, comply with the data retention obligations, and protect the data confidentiality.Reference:CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 1: Manage data inventory.

Evaluating operations, systems, and processes is best described as 'auditing', as it involves conducting a systematic and independent examination of the organization's privacy practices and controls to verify their effectiveness and compliance. The other options are more related to other forms of monitoring, such as complaint handling, reporting, and third-party oversight.Reference:CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 5: Monitor privacy program performance.