Which of the following is NOT an important factor to consider when developing a data retention policy?

A. Technology resource.

B. Business requirement.

C. Organizational culture.

D. Compliance requirement

SCENARIO

Please use the following to answer the next QUESTION:

Perhaps Jack Kelly should have stayed in the U.S. He enjoys a formidable reputation inside the company, Special Handling Shipping, for his work in reforming certain "rogue" offices. Last year, news broke that a police sting operation had revealed a drug ring operating in the Providence, Rhode Island office in the United States. Video from the office's video surveillance cameras leaked to news operations showed a drug exchange between Special Handling staff and undercover officers.

In the wake of this incident, Kelly had been sent to Providence to change the "hands off" culture that upper management believed had let the criminal elements conduct their illicit transactions. After a few weeks under Kelly's direction, the

office became a model of efficiency and customer service. Kelly monitored his workers' activities using the same cameras that had recorded the illegal conduct of their former co-workers.

Now Kelly has been charged with turning around the office in Cork, Ireland, another trouble spot. The company has received numerous reports of the staff leaving the office unattended. When Kelly arrived, he found that even when present,

the staff often spent their days socializing or conducting personal business on their mobile phones. Again, he observed their behaviors using surveillance cameras. He issued written reprimands to six staff members based on the first day of

video alone.

Much to Kelly's surprise and chagrin, he and the company are now under investigation by the Data Protection Commissioner of Ireland for allegedly violating the privacy rights of employees. Kelly was told that the

company's license for the cameras listed facility security as their main use, but he does not know why this matters. He has pointed out to his superiors that the company's training programs on privacy protection and data collection mention

nothing about surveillance video.

You are a privacy protection consultant, hired by the company to assess this incident, report on the legal and compliance issues, and recommend next steps.

What should you advise this company regarding the status of security cameras at their offices in the United States?

A. Add security cameras at facilities that are now without them.

B. Set policies about the purpose and use of the security cameras.

C. Reduce the number of security cameras located inside the building.

D. Restrict access to surveillance video taken by the security cameras and destroy the recordings after a designated period of time.

SCENARIO

Please use the following to answer the next QUESTION:

As they company's new chief executive officer, Thomas Goddard wants to be known as a leader in data

protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically Questionable practices, including unauthorized sales of personal data to marketers. Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company's claims that "appropriate" data protection safeguards were in place. The scandal affected the company's business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard's mentor, was forced to step down.

Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company's board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures. He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. "We want Medialite to have absolutely the highest standards," he says. "In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company's finances. So, while I want the best solutions across the board, they also need to be cost effective." You are told to report back in a week's time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.

What metric can Goddard use to assess whether costs associated with implementing new privacy protections are justified?

A. Compliance ratio

B. Cost-effective mean

C. Return on investment

D. Implementation measure

SCENARIO

Please use the following to answer the next QUESTION:

As the Director of data protection for Consolidated Records Corporation, you are justifiably pleased with your accomplishments so far. Your hiring was precipitated by warnings from regulatory agencies following a series of relatively minor data breaches that could easily have been worse. However, you have not had a reportable incident for the three years that you have been with the company. In fact, you consider your program a model that others in the data storage industry may note in their own program development. You started the program at Consolidated from a jumbled mix of policies and procedures and worked toward coherence across departments and throughout operations. You were aided along the way by the program's sponsor, the vice president of operations, as well as by a Privacy Team that started from a clear understanding of the need for change.

Initially, your work was greeted with little confidence or enthusiasm by the company's "old guard" among both the executive team and frontline personnel working with data and interfacing with clients. Through the use of metrics that showed the costs not only of the breaches that had occurred, but also projections of the costs that easily could occur given the current state of operations, you soon had the leaders and key decision-makers largely on your side. Many of the other employees were more resistant, but face-to-face meetings with each department and the development of a baseline privacy training program achieved sufficient "buy-in" to begin putting the proper procedures into place.

Now, privacy protection is an accepted component of all current operations involving personal or protected data and must be part of the end product of any process of technological development. While your approach is not systematic, it is fairly effective.

You are left contemplating:

What must be done to maintain the program and develop it beyond just a data breach prevention program? How can you build on your success?

What are the next action steps?

What analytic can be used to track the financial viability of the program as it develops?

A. Cost basis.

B. Gap analysis.

C. Return to investment.

D. Breach impact modeling.

SCENARIO

Please use the following to answer the next question:

Felicity is the Chief Executive Officer (CEO) of an international clothing company that does business in several countries, including the United States (U.S.), the United Kingdom (UK), and Canada. For the first five years under Felicity's

leadership, the company was highly successful due its higher profile on the Internet via target advertising and the use of social media. However, business has dropped in recent months, and Felicity is looking to cut costs across all

departments.

She has prepared to meet with the Chief Information Officer (CIO), Jin, who is also head of the company's privacy program.

After reviewing many of Jin's decisions, Felicity firmly believes that, although well-intentioned, Jin overspends company resources. Felicity has taken several notes on ways she believes the company can spend less money trying to uphold its

privacy mission. First, Felicity intends to discuss the size of the company's information security budget with Jin. Felicity proposes to streamline information security by putting it solely within the purview of the company's Information Technology

(IT) experts, since personal data within the company is stored electronically.

She is also perplexed by the Privacy Impact Assessments (PIAs) Jin facilitated at some of the company's locations. Jin carefully documented the approximate amount of man-hours the PIAs took to complete, and Felicity is astounded at the

amount. She cannot understand why so much time has been spent on sporadic PIAs.

Felicity has also recently received complaints from employees, including mid-level managers, about the great burden of paperwork necessary for documenting employee compliance with the company's privacy policy. She hopes Jin can

propose cheaper, more efficient ways of monitoring compliance. In Felicity's view, further evidence of Jin's overzealousness is his insistence on monitoring third-party processors for their observance of the company's privacy policy. New staff

members seem especially overwhelmed. Despite the consistent monitoring, two years ago the company had to pay remediation costs after a security breach of a processor's data system. Felicity wonders whether processors can be held

contractually liable for the costs of any future breaches.

Last in Felicity's notes is a reminder to discuss Jin's previous praise for the company's independent ethics function within the Human Resources (HR) department. Felicity believes that much company time could be saved if the Ethics Officer

position were done away with, and that any ethical concerns were simply brought directly to the executive leadership of the company.

Although Felicity questions many of Jin's decisions, she hopes that their meeting will be productive and that Jin, who is widely respected throughout the company, will help the company save money. Felicity believes that austerity is the only

way forward.

If all of Felicity's changes are enacted, who within the company would be most in danger of having little recourse?

A. Those who want to report wrongdoing.

B. Those who need better access to data.

C. Those who receive professional development.

D. Those who were recently hired to process data.