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IAPP Exam CIPM Topic 6 Question 68 Discussion

Actual exam question for IAPP's Certified Information Privacy Manager (CIPM) exam
Question #: 68
Topic #: 6
[All Certified Information Privacy Manager (CIPM) Questions]

Your company wants to convert paper records that contain customer personal information into electronic form, upload the records into a new third-party marketing tool and then merge the customer personal information in the marketing tool with information from other applications.

As the Privacy Officer, which of the following should you complete to effectively make these changes?

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Suggested Answer: D

A Privacy Impact Assessment (PIA) is a process that helps an organization identify and evaluate the potential privacy risks and impacts of a new or existing project, program, system, or service that involves the collection, use, disclosure, or retention of personal information. A PIA also helps an organization identify and implement appropriate measures to mitigate or eliminate those risks and impacts, and ensure compliance with applicable privacy laws, regulations, and standards. A PIA should be completed to effectively make changes that involve customer personal information, such as converting paper records into electronic form, uploading the records into a new third-party marketing tool, and merging the customer personal information in the marketing tool with information from other applications. A PIA can help an organization assess the necessity, proportionality, and legality of the proposed changes, as well as the potential privacy risks to the customers and the organization, such as unauthorized access, disclosure, modification, or loss of personal information, identity theft, fraud, reputational damage, or legal liability. A PIA can also help an organization implement appropriate measures to mitigate or eliminate those risks, such as data minimization, encryption, anonymization, pseudonymization, consent management, access control, security safeguards, contractual clauses, data protection impact assessments (DPIAs), data subject rights, breach notification procedures, and privacy policies.


CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section C: Monitoring and Managing Program Performance Subsection 1: Privacy Impact Assessments1

CIPM Study Guide (2021), Chapter 9: Monitoring and Managing Program Performance Section 9.1: Privacy Impact Assessments2

CIPM Textbook (2019), Chapter 9: Monitoring and Managing Program Performance Section 9.1: Privacy Impact Assessments3

CIPM Practice Exam (2021), Question 1464

Contribute your Thoughts:

Jamie
8 days ago
I think the correct answer is D) A Privacy Impact Assessment (PIA). Converting paper records to electronic form and sharing personal information with a third-party tool definitely requires a thorough assessment of the privacy risks.
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Argelia
22 days ago
I think both a PIA and a Personal Data Inventory would be necessary to ensure we are compliant and protect customer data.
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Kris
26 days ago
But wouldn't a Personal Data Inventory also be important to understand what customer information we have?
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Callie
1 months ago
I agree with Lucina, a PIA would help us identify and mitigate any privacy risks.
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Lucina
1 months ago
I think we should complete a Privacy Impact Assessment (PIA) for this.
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