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IAPP Exam CIPM Topic 3 Question 46 Discussion

Actual exam question for IAPP's CIPM exam
Question #: 46
Topic #: 3
[All CIPM Questions]

SCENARIO

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 notification, which of the following would be the greatest concern?

Show Suggested Answer Hide Answer
Suggested Answer: C

Contribute your Thoughts:

Rima
1 days ago
I'm with Lajuana on this one. The vendor already messed up once, so trusting them to handle the notification is a risky move. The company should take more control of the process.
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Hubert
6 days ago
Ha! I'm just picturing the vendor's logo on the postcard - 'Oops, our bad, but here's a free ad for us!' Not a good look for the company.
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Ashleigh
12 hours ago
It does seem a bit odd to have the vendor's logo on the postcard, especially after their mistake.
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Elmira
12 days ago
I disagree, I think the biggest issue is B - collecting more PII than necessary. The company should only ask for the minimum information required to provide updates.
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Emiko
3 days ago
But what if the affected individuals' data was not the only one compromised? That could be a huge problem.
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Laine
5 days ago
I think the biggest concern is D - trusting the vendor to send out the notice after failing to encrypt the database.
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Lajuana
21 days ago
The answer is C, using the vendor's logo on the postcard is the biggest concern. It could be seen as shifting blame to the vendor rather than taking responsibility as the data controller.
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Gladys
4 days ago
We should take responsibility for the data breach and not try to pass it off to the vendor.
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Ludivina
8 days ago
Using the vendor's logo on the postcard could make it seem like we are shifting blame.
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Troy
24 days ago
But what about option A? Informing affected individuals about potential data breach is crucial too.
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Georgene
30 days ago
I agree with Starr, trusting the vendor again seems risky.
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Starr
1 months ago
I think the greatest concern would be option D.
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a