DCPLA Online Practice Questions and Answers

What are the Nine Privacy Principles as described in DSCI Privacy Framework (DPF??

I) Use Limitation II) Accountability III) Data Quality IV) Notice V) Preventing Harm VI) Choice and Consent VII) Access and Correction VIII) Data Minimization IX) Openness X) Disclosure to Third Parties XI) Right to be Forgotten XII) Collection limitation XIII) Security

A. I, II, III, IV, V, VI, VII, VIII, IX

B. I, II, IV, V, VI, VII, IX, X, XII, XIII

C. I, II, III, IV, V, VI, VII, VIII, XII

D. I, II, III, IV, VII, VIII, IX, X, XI

With respect to privacy monitoring and incident management process, which of the following should be a part of a standard incident handling process?

I) Incident identification and notification II) Investigation and remediation III) Root cause analysis IV) User awareness training on how to report incidents

A. I and II

B. III and IV

C. I, II and III

D. All of the Above

Which of the following is not an objective of POR?

A. Create an inventory of business processes, enterprise and operational functions, client relationships that deal with personal information

B. Identify all the activities, functions and operations that can be attributed to the privacy initiatives of an organization

C. Evaluate the role of corporate function in legal compliance management, its relations with IT, and security functions. Evaluate the role of legal function in compliance matters

D. Establish a privacy function to address the activities, functions and operations that are required to manage the privacy initiatives

In the landmark case _______________ the Honourable Supreme Court of India reaffirmed the status of Right to Privacy as a Fundamental Right under Part III of the constitution.

A. M. P. Sharma and others vs. Satish Chandra, District Magistrate, Delhi, and others

B. Maneka Gandhi vs. Union of India

C. Justice K. S. Puttaswamy (Retd.) and Anr. vs. Union of India And Ors

D. Olga Tellis vs. Bombay Municipal Corporation

The method of personal data usage in which the users must explicitly decide not to participate.

A. Opt-In

B. Opt-out

C. Data mining

D. Data matching

VPI

As a starting point, the consultants undertook a visibility exercise to understand the type of personal information (PI) being dealt with within the organization and also by third parties and the scope was to cover all the client relationships (IT services and BPM both) and functions. They met with the client relationship and business function owners to collect this data. The consultants did a mapping exercise to identify PI and associated attributes including whether company directly collects the PI, how it is accessed, transmitted, stored and what are the applicable regulatory and contractual requirements. Given the enormous scale of the exercise (enterprise wide), the consultant classified the PI as financial information, health related information, personally identifiable information, etc. and collected the rest of the attributes against this classification. When understanding the underlying technology environment, the consultants restricted themselves only to the technology environment that was under company's ownership and premises and did not continue the exercise for client side environment. This was done because relationship owners seemed reluctant to share such client specific details. Only in 2 relationships, were the relationship heads proactive to introduce the consultants to the clients and get the requisite information. The analysis of the environment in these 2 relationships revealed that even though lots of restrictions were imposed at the company side, the same restrictions were not available at the client side.

Many business functions were also availing services from third party service providers. Though these functions were aware of the type of PI dealt by third parties, they were not aware of the technology environment at the third parties. In one odd case, personal information of a company employee was accidentally leaked by the employee of the third party through the social networking site. The consultants relied on whatever information was provided by the functions w.r.t. third parties. After finishing the data collection, the consultant used the information to create information flow maps highlighting the flow of information across systems deployed at the company premises. This work helped them have a high level view of PI dealt by the company. The data collection exercise has been conducted only once by the consultants. The visibility exercise empowered the management to have a company-wide view of PI and how it flows across the organization. This information was coupled with the security controls / practices deployed at the relationship or function level to derive the risk posture of the PI.

(Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion)

Introduction and Background

XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than 500 clients across industry verticals -- BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.

The company is witnessing phenomenal growth in the BPM services over last few years including Finance and Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects.

The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).

To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens. The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.

Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.

Was the visibility exercise adequately carried out? What gaps did you notice? (250 to 500 words)

A. See the answer in explanation below.

B. PlaceHolder

C. PlaceHolder

D. PlaceHolder

Section 43A of the Information Technology (Amendment) Act, 2008 holds____________ accountable for having reasonable security practices and procedures in place to protection sensitive personal data.

A. Government

B. Body corporates

C. Government and body corporates alike

D. None of the above

XYZ bank has recently decided to start offering online banking services. For doing so, the bank has outsourced its IT operations and processes to various third parties. Acknowledging privacy concerns, bank has decided to implement a privacy program. Assuming you have been tasked to deploy this framework for the bank, which of the following would most likely be your first step?

A. Create an inventory of business processes that deal with personal information and identify the associated data element

B. Ensure that bank is equipped to test the relevance of each legal and compliance requirement in its environment

C. Assign privacy roles and responsibilities for process owners

D. None of the above

Which of the following factors is least likely to be considered while implementing or augmenting data security solution for privacy protection?

A. Security controls deployment at the database level

B. Information security infrastructure up-gradation in the organization

C. Classification of data type and its usage by various functions in the organization

D. Training and awareness program for third party organizations

The concept of data adequacy is based on the principle of _________.

A. Adequate compliance

B. Dissimilarity of legislations

C. Essential equivalence

D. Essential assessment

Its mandatory for the assessee to provide the pre-requisites to the assessor organization before commencement of the first phase of assessment.

A. True

B. False

"Data which cannot be attributed to a particular data subject without use of additional information." Which of the following best describes the above statement?

A. Anonymized Data

B. Metadata

C. Pseudonymized Data

D. None of the above

What is a Data Subject? (Choose all that apply.)

A. An individual who provides his/her data/information for availing any service

B. An individual who processes the data/information of individuals for providing necessary services

C. An individual whose data/information is processed

D. A company providing PI of its employees for processing

E. An individual who collects data from illegitimate sources

Can a DSCI Certified Lead Assessor for Privacy, not currently an employee of a DSCI Accredited Organization, conduct external assessment leading to DSCI Privacy certification?

A. True

B. False

What is a Data Controller?

A. Entity that collects personal data

B. Entity that stores personal data

C. Entity that determines the purpose and means for data processing

D. Entity that shares personal data with third parties