SCENARIO
You have just been hired by Ancillary.com, a seller of accessories for everything under the sun, including waterproof stickers for pool floats and decorative bands and cases for sunglasses. The company sells cell phone cases, e-cigarette cases, wine spouts, hanging air fresheners for homes and automobiles, book ends, kitchen implements, visors and shields for computer screens, passport holders, gardening tools and lawn ornaments, and catalogs full of health and beauty products. The list seems endless. As the CEO likes to say, Ancillary offers, without doubt, the widest assortment of low-price consumer products from a single company anywhere.
Ancillary's operations are similarly diverse. The company originated with a team of sales consultants selling home and beauty products at small parties in the homes of customers, and this base business is still thriving. However, the company now sells online through retail sites designated for industries and demographics, sites such as “My Cool Ride" for automobile-related products or “Zoomer” for gear aimed toward young adults. The company organization includes a plethora of divisions, units and outrigger operations, as Ancillary has been built along a decentered model rewarding individual initiative and flexibility, while also acquiring key assets. The retail sites seem to all function differently, and you wonder about their compliance with regulations and industry standards. Providing tech support to these sites is also a challenge, partly due to a variety of logins and authentication protocols.
You have been asked to lead three important new projects at Ancillary:
The first is the personal data management and security component of a multi-faceted initiative to unify the company’s culture. For this project, you are considering using a series of third- party servers to provide company data and approved applications to employees.
The second project involves providing point of sales technology for the home sales force, allowing them to move beyond paper checks and manual credit card imprinting.
Finally, you are charged with developing privacy protections for a single web store housing all the company’s product lines as well as products from affiliates. This new omnibus site will be known, aptly, as “Under the Sun.” The Director of Marketing wants the site not only to sell Ancillary’s products, but to link to additional products from other retailers through paid advertisements. You need to brief the executive team of security concerns posed by this approach.
Which should be used to allow the home sales force to accept payments using smartphones?
Correct Answer:
C
SCENARIO
Clean-Q is a company that offers house-hold and office cleaning services. The company receives requests from consumers via their website and telephone, to book cleaning services. Based on the type and size of service, Clean-Q then contracts individuals that are registered on its resource database - currently managed in-house by Clean-Q IT Support. Because of Clean-Q's business model, resources are contracted as needed instead of permanently employed.
The table below indicates some of the personal information Clean-Q requires as part of its business operations:
Clean-Q has an internal employee base of about 30 people. A recent privacy compliance exercise has been conducted to align employee data management and human resource functions with applicable data protection regulation. Therefore, the Clean-Q permanent employee base is not included as part of this scenario.
With an increase in construction work and housing developments, Clean-Q has had an influx of requests for cleaning services. The demand has overwhelmed Clean-Q's traditional supply and demand system that has caused some overlapping bookings.
Ina business strategy session held by senior management recently, Clear-Q invited vendors to present potential solutions to their current operational issues. These vendors included Application developers and Cloud-Q’s solution providers, presenting their proposed solutions and platforms.
The Managing Director opted to initiate the process to integrate Clean-Q's operations with a cloud solution (LeadOps) that will provide the following solution one single online platform: A web interface that Clean-Q accesses for the purposes of resource and customer management. This would entail uploading resource and customer information.
A customer facing web interface that enables customers to register, manage and submit cleaning service requests online.
A resource facing web interface that enables resources to apply and manage their assigned jobs. An online payment facility for customers to pay for services.
What is a key consideration for assessing external service providers like LeadOps, which will conduct
personal information processing operations on Clean-Q's behalf?
Correct Answer:
D
What would be an example of an organization transferring the risks associated with a data breach?
Correct Answer:
C
To comply with the Sarbanes-Oxley Act (SOX), public companies in the United States are required to annually report on the effectiveness of the auditing controls of their financial reporting systems. These controls must be implemented to prevent unauthorized use, disclosure, modification, and damage or loss of financial data.
Why do these controls ensure both the privacy and security of data?
Correct Answer:
C
SCENARIO
WebTracker Limited is a cloud-based online marketing service located in London. Last year, WebTracker migrated its IT infrastructure to the cloud provider AmaZure, which provides SQL Databases and Artificial Intelligence services to WebTracker. The roles and responsibilities between the two companies have been formalized in a standard contract, which includes allocating the role of data controller to WebTracker.
The CEO of WebTracker, Mr. Bond, would like to assess the effectiveness of AmaZure's privacy controls, and he recently decided to hire you as an independent auditor. The scope of the engagement is limited only to the marketing services provided by WebTracker, you will not be evaluating any internal data processing activity, such as HR or Payroll.
This ad-hoc audit was triggered due to a future partnership between WebTracker and SmartHome — a partnership that will not require any data sharing. SmartHome is based in the USA, and most recently has dedicated substantial resources to developing smart refrigerators that can suggest the recommended daily calorie intake based on DNA information. This and other personal data is collected by WebTracker.
To get an idea of the scope of work involved, you have decided to start reviewing the company's documentation and interviewing key staff to understand potential privacy risks.
The results of this initial work include the following notes: There are several typos in the current privacy notice of WebTracker, and you were not able to find the privacy notice for SmartHome. You were unable to identify all the sub-processors working for SmartHome. No subcontractor is indicated in the cloud agreement with AmaZure, which is responsible for the support and maintenance of the cloud infrastructure. There are data flows representing personal data being collected from the internal employees of WebTracker, including an interface from the HR system. Part of the DNA data collected by WebTracker was from employees, as this was a prototype approved by the CEO of WebTracker. All the WebTracker and SmartHome customers are based in USA and Canada.
Based on the initial assessment and review of the available data flows, which of the following would be the most important privacy risk you should investigate first?
Correct Answer:
C
