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IAPP CIPM Exam - Topic 6 Question 51 Discussion

Posted by Charlene on Sep 03, 2023 at 02:54 PM

SCENARIO

Please use the following to answer the next QUESTION:

Your organization, the Chicago (U.S.)-based Society for Urban Greenspace, has used the same vendor to operate all aspects of an online store for several years. As a small nonprofit, the Society cannot afford the higher-priced options, but you have been relatively satisfied with this budget vendor, Shopping Cart Saver (SCS). Yes, there have been some issues. Twice, people who purchased items from the store have had their credit card information used fraudulently subsequent to transactions on your site, but in neither case did the investigation reveal with certainty that the Society's store had been hacked. The thefts could have been employee-related.

Just as disconcerting was an incident where the organization discovered that SCS had sold information it had collected from customers to third parties. However, as Jason Roland, your SCS account representative, points out, it took only a phone call from you to clarify expectations and the ''misunderstanding'' has not occurred again.

As an information-technology program manager with the Society, the role of the privacy professional is only one of many you play. In all matters, however, you must consider the financial bottom line. While these problems with privacy protection have been significant, the additional revenues of sales of items such as shirts and coffee cups from the store have been significant. The Society's operating budget is slim, and all sources of revenue are essential.

Now a new challenge has arisen. Jason called to say that starting in two weeks, the customer data from the store would now be stored on a data cloud. ''The good news,'' he says, ''is that we have found a low-cost provider in Finland, where the data would also be held. So, while there may be a small charge to pass through to you, it won't be exorbitant, especially considering the advantages of a cloud.''

Lately, you have been hearing about cloud computing and you know it's fast becoming the new paradigm for various applications. However, you have heard mixed reviews about the potential impacts on privacy protection. You begin to research and discover that a number of the leading cloud service providers have signed a letter of intent to work together on shared conventions and technologies for privacy protection. You make a note to find out if Jason's Finnish provider is signing on.

What is the best way to prevent the Finnish vendor from transferring data to another party?

Suggested Answer: B

The first stage in the incident response plan under the General Data Protection Regulation (GDPR) for this scenario would be to contain the impact of the breach. This means taking immediate action to stop the unauthorized access or disclosure of personal data, and to prevent it from happening again in the future. This could involve revoking access to the data, notifying the employee who mistakenly sent the data, and implementing security measures to prevent similar breaches from occurring in the future.


https://gdpr-info.eu/art-33-gdpr/

https://gdpr-info.eu/art-34-gdpr/

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40 comments · newest first
MI
Micaela 11 months ago
Offering resources to help sounds nice, but we need strict controls!
AD
Adelaide 12 months ago
SCS has had issues before, but the sales are crucial for us.
VI
Vicky 12 months ago
Wait, a Finnish vendor? Sounds sketchy to me.
SH
Shanice 1 year ago
Totally agree, gotta include those transfer prohibitions in the contract!
FR
Frankie 1 year ago
I heard cloud storage can be risky for privacy.
CA
Casie 1 year ago
I have a vague recollection that restricting security controls could help, but I wonder if that’s really enforceable with a third-party vendor.
YO
Yong 1 year ago
I practiced a similar question about data privacy last week, and I think offering resources might not directly prevent data transfer, so it seems less effective.
AD
Adelle 1 year ago
I'm not entirely sure, but I feel like just locking the data down might not be enough if the vendor has access.
EL
Eliz 1 year ago
I remember discussing vendor contracts in class, and I think including transfer prohibitions could be crucial to ensure data stays protected.
LA
Lashawna 1 year ago
Based on the information provided, I think the clear choice is to include transfer prohibitions in the vendor contract. That seems like the most direct way to prevent the Finnish provider from sharing the data without our consent. We need to take a firm stance on protecting customer privacy.
GE
German 1 year ago
I'm a bit confused by all the options here. I'll need to do some more research on cloud computing and privacy best practices to figure out the right way to handle this. Restricting the vendor's security controls or offering our own resources could be possibilities.
AU
Audra 1 year ago
This seems like a tricky situation with the vendor moving customer data to a cloud provider in Finland. I'll need to carefully review the options to ensure we protect customer privacy while also considering the financial impact.
CE
Ceola 1 year ago
Hmm, the vendor's actions are concerning, especially with the previous privacy issues. I think the best approach is to include strict transfer prohibitions in the contract to prevent the data from being shared with any other parties.
FA
Fannie 1 year ago
This question seems straightforward. I think the answer is SaaS since the cloud provider takes on the most responsibility for application-level controls in that model.
AU
Audra 1 year ago
Okay, let's see. The tunnel from spoke to hub is not coming up, so I'm guessing it could be either a mismatch in the edge models or a mismatch in the certificate authentication mode. I'll make sure to double-check those settings.
ER
Eric 1 year ago
Okay, let's see. We need the computer to be able to send the print job to the printer, so we definitely need some kind of driver software. The other options don't seem as relevant. I'll go with B.
IO
Iola 2 years ago
Hold up, did you say the vendor sold customer data before? I wouldn't trust them as far as I could throw them. Contract or bust!
TH
Therese 1 year ago
↳ replying to Iola
C) Include transfer prohibitions in the vendor contract
SU
Susy 1 year ago
↳ replying to Iola
A) Restrict the vendor to using company security controls
IV
Ivette 1 year ago
↳ replying to Iola
C) Include transfer prohibitions in the vendor contract
RO
Rozella 2 years ago
Company resources to assist with the processing? Sounds like a lot of work. I'd just keep it simple and go with the contract option.
LE
Leslee 1 year ago
↳ replying to Rozella
C) Include transfer prohibitions in the vendor contract
LE
Leslee 1 year ago
↳ replying to Rozella
A) Restrict the vendor to using company security controls
LE
Leslee 1 year ago
↳ replying to Rozella
C) Include transfer prohibitions in the vendor contract
TA
Tawna 2 years ago
Ooh, I heard about those cloud providers working on privacy protection! Maybe Jason's Finnish vendor is part of that group. Either way, I'd definitely want to include transfer prohibitions in the contract.
RI
Rikki 1 year ago
↳ replying to Tawna
Definitely, we need to make sure our data is secure and not being passed around without our knowledge.
NG
Nguyet 1 year ago
↳ replying to Tawna
I think that's the best way to prevent any unauthorized sharing of the data.
DE
Dell 1 year ago
↳ replying to Tawna
I agree, it's important to make sure the vendor can't just transfer the data to anyone without permission.
GA
Gail 1 year ago
↳ replying to Tawna
That's a good point, including transfer prohibitions in the contract would definitely help protect the data.
HA
Harley 2 years ago
Locking the data down in its current location seems a bit extreme. I'd rather try to work with the vendor and include contractual provisions to protect the data.
BA
Barabara 1 year ago
↳ replying to Harley
User 2
AD
Adelina 1 year ago
↳ replying to Harley
User 1
BE
Beckie 1 year ago
↳ replying to Harley
Offering company resources to assist with processing could be beneficial in maintaining control over the data.
SU
Suzan 1 year ago
↳ replying to Harley
Restricting the vendor to using company security controls could also help ensure the data stays secure.
HO
Holley 2 years ago
↳ replying to Harley
It's important to have clear guidelines in place to protect the data from being transferred to unauthorized parties.
SA
Salome 2 years ago
↳ replying to Harley
I agree, working with the vendor and including transfer prohibitions in the contract seems like a more reasonable approach.
MI
Millie 2 years ago
I think the best way would be to include transfer prohibitions in the vendor contract. That way, there's a legal agreement in place to prevent the data from being transferred elsewhere.
AN
Angelica 2 years ago
I'm not sure, maybe we should also consider option A, restricting the vendor to using company security controls.
RE
Renea 2 years ago
I agree with Paulina, that seems like the best way to prevent data transfer to another party.
PA
Paulina 2 years ago
I think we should go with option C, include transfer prohibitions in the vendor contract.
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