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DSCI Certified Privacy Lead Assessor DCPLA certification Sample Questions:

1. Which of the following is not an objective of POR?

A) Identify all the activities, functions and operations that can be attributed to the privacy initiatives of an organization
B) Establish a privacy function to address the activities, functions and operations that are required to manage the privacy initiatives
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

2. 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 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.
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)

3. 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 collects data from illegitimate sources
C) An individual whose data/information is processed
D) A company providing PI of its employees for processing
E) An individual who processes the data/information of individuals for providing necessary services

4. 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 the organization and associated third parties
B) 'Data processing environment' analysis of industry peers
C) 'Data processing environment' analysis of the country
D) 'Data processing environment' analysis of the organization only

5. An entity shall retain personal data only as long as may be reasonably necessary to satisfy the purpose for which it is processed; or with respect to an established retention period. This privacy principle is known as?

A) Use Limitation
B) Collection Limitation
C) Storage Limitation
D) Security safeguards

Solutions: