Isaca Updated CDPSE Exam Questions and Answers by aris

Any organization collecting information about EU residents is required to operate with transparency in collecting and using their personal information. Chapter III of the GDPR defines eight data subject rights that have become foundational for other privacy regulations around the world:

Right to access personal data. Data subjects can access the data collected on them.

One of the privacy requirements related to the rights of data subjects is the right to access, which means that individuals have the right to obtain a copy of their personal data, as well as information about how their data is processed, by whom, for what purposes, and for how long. To meet this requirement, an organization’s technology stack should incorporate features that allow individuals to have direct access to their data, such as self-service portals, dashboards, or applications. This way, individuals can exercise their right to access without relying on intermediaries or manual processes, which can be inefficient, error-prone, or insecure. References: : CDPSE Review Manual (Digital Version), page 137

Obtaining executive support is the first step in developing an organization-wide strategy to address data privacy risk, as it ensures that the privacy program has the necessary resources, authority, and alignment with the organization’s goals and objectives. Without executive support, the privacy program may face challenges in implementing and enforcing privacy policies, procedures, and controls across the organization. References: 2 Domain 1, Task 1

A retention schedule is a document that specifies how long different types of records or data should be kept and when they should be deleted or disposed of, based on legal, regulatory, operational or historical requirements. A retention schedule is the best indication of an effective records management program for personal data, as it reflects the principles of data minimization and storage limitation, which require limiting the collection, storage and processing of personal data to what is necessary and relevant for the intended purposes, and deleting or disposing of personal data when it is no longer needed or justified. A retention schedule also helps to reduce the privacy risks and costs associated with data storage and retention, such as data breaches, unauthorized access, misuse or loss of data. The other options are not as indicative of an effective records management program for personal data as a retention schedule. Archived data is used for future analytics may indicate that the organization is leveraging its data assets for business intelligence or research purposes, but it may not comply with the principles of data minimization and storage limitation, or the privacy rights and preferences of the data subjects. The legal department has approved the retention policy may indicate that the organization has obtained legal advice or guidance on its records management program for personal data, but it may not reflect the actual implementation or execution of the retention policy. All sensitive data has been tagged may indicate that the organization has implemented a data classification scheme for its records or data, but it may not indicate how long the records or data should be kept or when they should be deleted or disposed of1, p. 99-100 References: 1: CDPSE Review Manual (Digital Version)

A data loss prevention (DLP) tool is a software solution that monitors, detects and prevents the unauthorized transmission or leakage of sensitive data, such as personal data, from an organization’s network or devices. A DLP tool can help to ensure the effectiveness of a policy requiring the encryption of personal data if transmitted through email, by applying the following controls:

• Scanning the content and attachments of outgoing emails for personal data, such as names, email addresses, biometric data, IP addresses, etc.
• Blocking or quarantining emails that contain unencrypted personal data, and alerting the sender and/or the administrator of the policy violation.
• Encrypting personal data automatically before sending them through email, using encryption standards and algorithms that are compliant with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA).
• Generating audit logs and reports of email activities and incidents involving personal data, and providing visibility and accountability for policy compliance.

The other options are less effective or irrelevant to ensure the effectiveness of the policy. Providing periodic user awareness training on data encryption is a good practice, but it does not guarantee that users will follow the policy or know how to encrypt personal data properly. Conducting regular control self-assessments (CSAs) is a useful method to evaluate the design and operation of the policy, but it does not prevent or detect policy violations in real time. Enforcing annual attestation to policy compliance is a formal way to demonstrate user commitment to the policy, but it does not verify or measure the actual level of compliance.

References:

• The Complexity Conundrum: Simplifying Data Security - ISACA, section 3: “Data loss prevention (DLP) solutions can help prevent unauthorized access to sensitive information by monitoring network traffic for specific keywords or patterns.”
• Guide to Securing Personal Data in Electronic Medium, section 3.2: “Organisations should consider implementing DLP solutions to prevent unauthorised disclosure of personal data via email.”
• Encryption in the Hands of End Users - ISACA, section 2: “A key goal of encryption is to protect the file even when direct access is possible or the transfer is intercepted.”