Accurate & Verified 2023 New DCPLA Answers As Experienced in the Actual Test!
DCPLA Certification Sample Questions certification Exam
The DCPLA certification exam covers a wide range of topics, including privacy laws and regulations, privacy management frameworks, privacy impact assessment, privacy audit, and incident management. DSCI Certified Privacy Lead Assessor DCPLA certification certification exam is designed to assess the candidate's knowledge and understanding of these topics, as well as their ability to apply this knowledge in real-world scenarios. DCPLA exam is conducted online and consists of multiple-choice questions.
NEW QUESTION # 20
Arrange the following techniques in decreasing order of the risk of re-identification:
I) Pseudonymization
II) De-identification
III) Anonymization
- A. II, III, I
- B. III, II, I
- C. I, II
- D. All have equal risk of re-identification
Answer: A
NEW QUESTION # 21
As a privacy assessor, what would most likely be the first artefact you would ask for while assessing an organization which claims that it has implemented a privacy program?
- A. Privacy risk management framework
- B. Personal information management policy
- C. Records of deployed privacy notices and statements
- D. Records of privacy specific training imparted to the employees handling personal information
Answer: A
NEW QUESTION # 22
What are the two phases of DSCI Privacy Third Party Assessment?
- A. Initial and Final
- B. None of the above
- C. Initial and Detailed
- D. Primary and Secondary
Answer: A
NEW QUESTION # 23
FILL BLANK
RCI and PCM
In April 2011, the rules were issued under Section 43A of the IT Act by the Government of India and the
'body corporates' were required to comply with these rules. The Corporate legal team tried to understand and interpret the rules but struggled to understand its applicability esp. to client relationships and business functions. So, the company hired an IT Act legal expert to advise them on the Section 43A rules.
To start with, the company identified the PI dealt with by business functions as part of the earlier visibility exercise, but it wanted to reassure itself. Therefore, a specific exercise was conducted to revisit 'sensitive personal information' dealt by business functions. It was realized that the company collects lot of SPI of its employees and therefore 'reasonable security practices' need to be adhered to by the functions that deal with SPI. It was also ascertained that many of this SPI is being dealt by third parties, some of which are also located outside India. To meet the requirements of the rules, the company reviewed all the contracts and inserted a clause - 'the service provider shall implement reasonable security practices and procedures as per the IT (Amendment) Act, 2008'. Some of the large service providers were ISO 27001 certified and they claimed that they fulfill the requirements of 'reasonable security practices'. However, some SME service providers did not understand what would 'reasonable security practices' imply and requested the company to clarify, which referred them to Rule 8 of the Section 43A. Some small scale service providers expressed their unwillingness to get ISO certified, given the costs involved.
(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 & 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.
Did the company take sufficient steps to protect SPI dealt by its service providers and ensure that it complies with the regulatory requirements? Was referring to 'reasonable security practices' sufficient in the contracts or the company should have also considered some other measures for privacy protection as well? (250 to 500 words)
Answer:
Explanation:
The consulting arm of XYZ developed a comprehensive privacy program in line with the company's goal to leverage its existing technology infrastructure, resources and capabilities for protecting data. The program had three parts - awareness and training, policy development and implementation. On the awareness front, extensive training was conducted for employees on various aspects of privacy including GDPR compliance.
This was followed by the development and rollout of an enterprise-wide privacy policy which clearly defined the various steps to be taken to protect sensitive personal information (SPI) such as encryption, access controls etc. After this, customer contracts were reviewed for appropriate protection clauses and service providers were made to sign 'reasonable security practices' clauses in their contractual obligations as specified in EU GDPR.
At first glance, it seemed that XYZ had taken adequate steps to protect SPI dealt by its service providers and ensure that it complies with the regulatory requirements. However, on careful scrutiny, there were some lacunae in the program. For instance, as per EU GDPR, personal data must be pseudonymized or encrypted prior to transfer from one entity to another. In this case, though encryption was mentioned in the policy documents but there were no specific measures given for ensuring proper encryption of data before any transfer. Similarly, 'reasonable security practices' clause was included in customer contracts but there was no mention of any tools like firewalls or other means of protecting sensitive information which could have further strengthened the privacy protection efforts made by the company.
Thus, it is clear that XYZ did made some efforts to comply with the EU GDPR but in order to ensure full compliance, more specific measures should have been taken and all contractual obligations must be such that they clearly define the security and privacy controls that need to be put in place between customer/client and service provider. This would further give customers greater assurance of privacy protection from XYZ's services. Going forward, XYZ can consider investing in more advanced technologies like biometrics authentication etc for maximum security of data. Furthermore, the company should also ensure periodic reviews of its policy documents and contracts so as to ensure better protection of sensitive personal information.
Overall, though XYZ took some reasonable steps to protect SPI of its customers, it should have done more by introducing advanced security measures and including stringent contractual obligations for service providers.
This would have enabled the company to achieve full compliance with EU GDPR and ensure greater security of customer's personal data.
NEW QUESTION # 24
Which of the following parameters should ideally be addressed by a privacy program of an organization?
(Choose all that apply.)
- A. Training and data classification
- B. Privacy incident response plan and grievance handling
- C. Environmental security concerns
- D. Intellectual Property (IP) protection
Answer: A,B
NEW QUESTION # 25
Which of the following are classified as Sensitive Personal Data or Information under Section 43A of ITAA, 2008? (Choose all that apply.)
- A. Financial information
- B. Medical records and history
- C. Sexual orientation
- D. Caste and religious beliefs
- E. Password
- F. Biometric information
Answer: A,B,C,F
NEW QUESTION # 26
Which among the following would not be characteristic of a good privacy notice?
- A. Easy to understand
- B. Multi-lingual
- C. Clear and concise
- D. Comprehensive - explaining all the possible scenarios and processing details making the notice lengthy
Answer: D
NEW QUESTION # 27
FILL BLANK
RCI and PCM
Given its global operations, the company is exposed to multiple regulations (privacy related) across the globe and needs to comply mostly through contracts for client relationships and directly for business functions. The corporate legal team is responsible for managing the contracts and understanding, interpreting and translating the legal requirements. There is no formal tracking of regulations done. The knowledge about regulations mainly comes through interaction with the client team. In most of the contracts, the clients have simply referred to the applicable legislations without going any further in terms of their applicability and impact on the company. Since business expansion is the priority, the contracts have been signed by the company without fully understanding their applicability and impact. Incidentally, when the privacy initiatives were being rolled out, a major data breach occurred at one of the healthcare clients located in the US. The US state data protection legislation required the client to notify the data breach. During investigations, it emerged that the data breach happened because of some vulnerability in the system owned by the client but managed by the company and the breach actually happened 5 months back and came to notice now. The system was used to maintain medical records of the patients. This vulnerability had been earlier identified by a third party vulnerability assessment of the system and the closure of vulnerability was assigned to the company. The company had made the requisite changes and informed the client. The client, however, was of the view that the changes were actually not made by the company and they therefore violated the terms of contract which stated that - "the company shall deploy appropriate organizational and technology measures for protection of personal information in compliance with the XX state data protection legislation." The company could not produce necessary evidences to prove that the configuration changes were actually made by it (including when these were made).
(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 & 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.
Why do you think the company failed to defend itself against client accusations? (250 to 500 words)
Answer:
Explanation:
The company failed to defend itself against accusations by its clients most likely due to the fact that it did not have enough expertise in privacy and data protection. The company's privacy program was designed and implemented by an internal consulting arm which had limited expertise in the domain, causing the program to be inadequate for the purpose of defending itself against accusations. Moreover, since the project was driven by CIO's office, there may have been a lack of coordination between different functions like Corporate Information Security and Legal functions which could also have contributed to the failure.
It is possible that there were gaps in the organizational measures deployed by XYZ as well as gaps in technology measures. For example, it is possible that although appropriate organizational measures were put in place, the technology measures were inadequate for protecting the sensitive data of its clients. In addition, it is possible that the company did not rigorously monitor compliance with these organizational and technological measures, thereby making it vulnerable to accusations by its clients.
It is also likely that XYZ was unable to fully comply with applicable privacy laws and regulations in the EU due to lack of awareness about their requirements as well as insufficient resources allocated for adapting to them. The EU GDPR requires companies to implement appropriate technical and organizational measures for the protection of personal data which could have been a challenge for XYZ given its limited expertise in this domain. Furthermore, even though it may have had some understanding of the legal requirements, there may have been difficulty in properly implementing them, which could have led to the accusations by its clients.
Finally, it is possible that XYZ failed to defend itself against client accusations because of a lack of communication between its different departments and functions. The company may not have had a clear understanding of the requirements and risks associated with data protection and privacy compliance which could have caused miscommunication among various stakeholders leading to inadequate responses when it was challenged by its clients.
Overall this case study demonstrates the importance of properly designing and implementing an effective privacy program in order to protect sensitive data from unauthorized access or misuse. Companies should ensure that they have adequate expertise in data protection as well as sufficient resources for adapting to changing regulatory requirements in order to avoid potential legal issues arising from client accusations.
Effective communication and coordination across different departments and functions is also essential for successful data protection compliance.
It is recommended that companies invest in an ongoing training program to ensure that employees understand the importance of privacy, have an awareness of the legal requirements, and are able to properly implement security measures to protect sensitive data. Organizations should also consider implementing automated tools and technologies such as encryption, access control systems, identity management solutions, etc., which can help them better defend themselves against potential client accusations.
NEW QUESTION # 28
Which of the following activities form part of an organization's Visibility over Personal Information (VPI) initiative, according to DSCI Privacy Framework (DPF)?
- A. 'Data processing environment' analysis of industry peers
- B. 'Data processing environment' analysis of the organization and associated third parties
- C. 'Data processing environment' analysis of the country
- D. 'Data processing environment' analysis of the organization only
Answer: B
NEW QUESTION # 29
Which of the following could be considered as triggers for updating privacy policy? (Choose all that apply.)
- A. Recruitment of more employees
- B. Regulatory changes
- C. Privacy breach
- D. Change in service provider for an established business process
Answer: B,C
NEW QUESTION # 30
What is a Data Subject? (Choose all that apply.)
- A. An individual whose data/information is processed
- B. An individual who processes the data/information of individuals for providing necessary services
- C. A company providing PI of its employees for processing
- D. An individual who collects data from illegitimate sources
- E. An individual who provides his/her data/information for availing any service
Answer: A,E
NEW QUESTION # 31
Which of the following is not an objective of VPI?
- A. To enable identification of processes, functions and relationships handling personal information
- B. Assess the current state of data spread and transactions of the organization to map this against its privacy objectives
- C. None of the above
- D. Enable an organization to map its data operations and categorization of PI
Answer: C
NEW QUESTION # 32
What is the maximum compensation that can be imposed on an organization for negligence in implementing reasonable security practices as defined in Section 43A of ITAA, 2008?
- A. 15 crores or 4% of the global turnover
- B. 5 crores
- C. Uncapped compensation
- D. 5 lakhs
Answer: A
NEW QUESTION # 33
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. False
- B. True
Answer: B
NEW QUESTION # 34
Which of the following statements is true with respect to organization's privacy training and awareness program?
- A. None of the above
- B. It should define roles and responsibilities of personnel in privacy function
- C. It should cover employees of service provider dealing with personal information
- D. It should necessarily cover officials from Law Enforcement Agencies that request lawful access to personal information
Answer: B
NEW QUESTION # 35
Which of the following are key contributors that would enhance the complexity in implementing security measures for protection of personal information? (Choose all that apply.)
- A. None of the above
- B. Data collection through multiple modes and channels
- C. Regulatory requirements to issue privacy notice and data breach notification in specified format
- D. Evolution of nimble and flexible business processes affecting access management
Answer: B,C,D
NEW QUESTION # 36
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. III and IV
- B. I, II and III
- C. All of the Above
- D. I and II
Answer: C
NEW QUESTION # 37
Which of the following is not an objective of POR?
- A. Establish a privacy function to address the activities, functions and operations that are required to manage the privacy initiatives
- 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. Create an inventory of business processes, enterprise and operational functions, client relationships that deal with personal information
Answer: C
NEW QUESTION # 38
__________ calls for inclusion of data protection from the onset of the designing of systems.
- A. Privacy by Design
- B. Logical Design
- C. Safeguarding Approach
- D. Agile Model
Answer: A
NEW QUESTION # 39
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