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Free IAPP CIPP-C Exam Questions

Which of the following types of information would an organization generally NOT be required to disclose to

Please use the following to answer the next QUESTION:

You are the chief privacy officer at HealthCo, a major hospital in a large U.S. city in state A. HealthCo is a

HIPAA-covered entity that provides healthcare services to more than 100,000 patients. A third-party cloud

computing service provider, CloudHealth, stores and manages the electronic protected health information

(ePHI) of these individuals on behalf of HealthCo. CloudHealth stores the data in state B. As part of

HealthCo’s business associate agreement (BAA) with CloudHealth, HealthCo requires CloudHealth to

implement security

measures, including industry standard encryption practices, to adequately protect the data. However, HealthCo

did not perform due diligence on CloudHealth before entering the contract, and has not conducted audits of

CloudHealth’s security measures.

A CloudHealth employee has recently become the victim of a phishing attack. When the employee

unintentionally clicked on a link from a suspicious email, the PHI of more than 10,000 HealthCo patients was

compromised. It has since been published online. The HealthCo cybersecurity team quickly identifies the

perpetrator as a known hacker who has launched similar attacks on other hospitals – ones that exposed the PHI

of public figures including celebrities and politicians.

During the course of its investigation, HealthCo discovers that CloudHealth has not encrypted the PHI in

accordance with the terms of its contract. In addition, CloudHealth has not provided privacy or security

training to its employees. Law enforcement has requested that HealthCo provide its investigative report of the

breach and a copy of the PHI of the individuals affected.

A patient affected by the breach then sues HealthCo, claiming that the company did not adequately protect the

individual’s ePHI, and that he has suffered substantial harm as a result of the exposed data. The patient’s

attorney has submitted a discovery request for the ePHI exposed in the breach.

What is the most significant reason that the U.S. Department of Health and Human Services (HHS) might

impose a penalty on HealthCo?

Because HealthCo did not require CloudHealth to implement appropriate physical and administrative

measures to safeguard the ePHI

Acme Student Loan Company has developed an artificial intelligence algorithm that determines whether an

individual is likely to pay their bill or default. A person who is determined by the algorithm to be more likely

to default will receive frequent payment reminder calls, while those who are less likely to default will not

receive payment reminders.

Which of the following most accurately reflects the privacy concerns with Acme Student Loan Company using

artificial intelligence in this manner?

If the algorithm uses risk factors that impact the automatic decision engine. Acme must ensure that the

algorithm does not have a disparate impact on protected classes in the output.

If the algorithm makes automated decisions based on risk factors and public information, Acme need not

determine if the algorithm has a disparate impact on protected classes.

If the algorithm’s methodology is disclosed to consumers, then it is acceptable for Acme to have a

disparate impact on protected classes.

If the algorithm uses information about protected classes to make automated decisions, Acme must

ensure that the algorithm does not have a disparate impact on protected classes in the output.

Implementing a system of standardization for privacy notices

Please use the following to answer the next QUESTION:

A US-based startup company is selling a new gaming application. One day, the CEO of the company receives

an urgent letter from a prominent EU-based retail partner. Triggered by an unresolved complaint lodged by an

EU resident, the letter describes an ongoing investigation by a supervisory authority into the retailer’s data

handling practices.

The complainant accuses the retailer of improperly disclosing her personal data, without consent, to parties in

the United States. Further, the complainant accuses the EU-based retailer of failing to respond to her

withdrawal of consent and request for erasure of her personal data. Your organization, the US-based startup

company, was never informed of this request for erasure by the EU-based retail partner. The supervisory

authority investigating the complaint has threatened the suspension of data flows if the parties involved do not

cooperate with the investigation. The letter closes with an urgent request: “Please act immediately by

identifying all personal data received from our company.”

This is an important partnership. Company executives know that its biggest fans come from Western Europe;

and this retailer is primarily responsible for the startup’s rapid market penetration.

As the Company’s data privacy leader, you are sensitive to the criticality of the relationship with the retailer.

Upon review, the data privacy leader discovers that the Company’s documented data inventory is obsolete.

What is the data privacy leader’s next best source of information to aid the investigation?

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