CIPP-US Exam Dumps : Certified Information Privacy Professional/United States (CIPP/US)

 According to the Privacy Shield Framework, an organization that transfers personal data to a third party acting as an agent must ensure that the agent does all of the following1:

Uses the transferred data only for limited and specified purposes;

Provides the same level of privacy protection as is required by the Privacy Shield Principles;

Takes reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with the organization’s obligations under the Principles;

Requires the agent to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles;

Upon notice, takes reasonable and appropriate steps to stop and remediate unauthorized processing; and

Provides a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department of Commerce upon request.

Therefore, the only option that is not required by the Privacy Shield Framework is D. Enters a contract with the organization that states the third party will process data according to the consent agreement. While the organization must obtain the individual’s consent for certain types of data transfers, such as those involving sensitive data or onward transfers to controllers, the organization does not have to include the consent agreement in the contract with the agent. The contract must, however, ensure that the agent will process the data in accordance with the individual’s choices and expectations, as well as the Privacy Shield Principles2.

References: 1: Privacy Shield Framework3, Section 3 (b); 2: Privacy Shield Framework3, Section 2 (b) and ©; 3: Privacy Shield Framework.

The annual privacy notice requirement under the Gramm-Leach-Bliley Act (GLBA) applies to financial institutions that collect nonpublic personal information from customers and disclose it to nonaffiliated third parties, unless they qualify for an exception. A financial institution is any entity that engages in activities that are financial in nature or incidental to such activities, as defined by section 4(k) of the Bank Holding Company Act of 1956. The King County Savings and Loan is a financial institution under this definition, as it engages in lending money and accepting deposits. Therefore, it is required to provide its customers with an annual privacy notice, unless it meets the conditions for an exception. The Four Winds Tribal College, the Golden Gavel Auction House, and the Breezy City Housing Commission are not financial institutions under the GLBA, as they do not engage in activities that are financial in nature or incidental to such activities. Therefore, they are not required to provide their customers with an annual privacy notice under the GLBA. References:

Amendment to the Annual Privacy Notice Requirement Under the Gramm-Leach-Bliley Act, section I. Background, paragraph 2.

17 CFR § 248.5 - Annual privacy notice to customers required., paragraph (a) (1).

IAPP CIPP/US Study Guide, page 65.

According to Section 5 of the FTC Act, self-regulation primarily involves a company’s right to adhere to its industry’s code of conduct. Self-regulation is a process by which an industry or a group of companies voluntarily adopts and enforces standards or guidelines to protect consumers and promote fair competition. The FTC encourages self-regulation as a way to complement its enforcement efforts and address emerging issues in the marketplace. The FTC also monitors self-regulatory programs and may take action against companies that fail to comply with their own codes of conduct or misrepresent their participation in such programs. References:

Federal Trade Commission Act, Section 5 of

Self-Regulation | Federal Trade Commission

[IAPP CIPP/US Certified Information Privacy Professional Study Guide], Chapter 3, page 79