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The right to be forgotten is a privacy right that allows individuals to request the deletion or removal of their personal data from a data controller’s records or systems under certain conditions. One of these conditions is when the data is no longer required for the purpose originally collected, meaning that the data has become obsolete, irrelevant or excessive for fulfilling the initial purpose for which it was obtained or processed by the data controller. The other options are not valid conditions for exercising the right to be forgotten. The data is being used to comply with legal obligations or public interest is an exception that may prevent the data controller from deleting or removing the data upon request, as there may be overriding legitimate grounds for retaining the data for legal compliance or public interest reasons. The individual objects despite legitimate grounds for processing is a condition for exercising the right to object, not the right to be forgotten, which allows individuals to oppose the processing of their personal data based on their particular situation or for direct marketing purposes. The individual’s legal residence status has recently changed is not a relevant factor for exercising the right to be forgotten, as it does not affect the necessity or relevance of the data for its original purpose1, p. 107-108 References: 1: CDPSE Review Manual (Digital Version)

The first step for an IT privacy practitioner following a decision to expand remote working capability is to evaluate the impact resulting from this change on the organization’s privacy policies, programs and practices. This will help identify the risks and gaps that need to be addressed, as well as the opportunities for improvement and optimization. The other options are possible actions that may be taken after the impact assessment, depending on the results and recommendations.

References:

• CDPSE Exam Content Outline, Domain 1 – Privacy Governance (Governance, Management & Risk Management), Task 1: Identify issues requiring remediation and opportunities for process improvement1.
• CDPSE Review Manual, Chapter 1 – Privacy Governance, Section 1.3 – Privacy Impact Assessment (PIA)2.

Requirements definition is a phase of the software development life cycle (SDLC) that involves gathering, analyzing and documenting the functional and non-functional requirements of the software system or application, such as features, performance, security and usability. It is most important to consider privacy by design principles during this phase, as it would help to ensure that privacy is embedded and integrated into the software system or application from the outset, rather than as an afterthought or an add-on. Considering privacy by design principles during requirements definition would also help to avoid costly rework or delays later in the SDLC, as well as to enhance customer trust and satisfaction, and comply with privacy laws and regulations. The other options are not as important as requirements definition in considering privacy by design principles. Application design is a phase of the SDLC that involves creating and specifying the architecture, components, interfaces and data models of the software system or application, based on the requirements defined in the previous phase. Implementation is a phase of the SDLC that involves coding, testing and debugging the software system or application, based on the design specifications created in the previous phase. Testing is a phase of the SDLC that involves verifying and validating that the software system or application meets the requirements and expectations of the users and stakeholders, as well as identifying and fixing any defects or errors1, p. 88-89 References: 1: CDPSE Review Manual (Digital Version)

Remote employee monitoring software is a solution that collects, analyzes and reports data on the activities and behaviors of employees who work remotely or from home. It can help organizations to measure and improve employee productivity, performance, engagement and security. However, it also poses significant privacy risks and challenges, as it may involve the collection and processing of personal data, such as names, email addresses, biometric data, IP addresses, keystrokes, screenshots, web browsing history, app usage, communication content and frequency, etc.

Data access should be restricted based on roles, meaning that only authorized and legitimate parties should be able to access and use the data collected by the remote employee monitoring software, based on their roles and responsibilities within the organization. This is a key privacy principle and practice that helps to protect the privacy rights and interests of the employees, and to prevent unauthorized or excessive access, use, disclosure or modification of their personal data by the organization or third parties. Data access restriction based on roles also helps to comply with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which require data controllers and processors to implement appropriate technical and organizational measures to safeguard personal data.

References:

• Mobile Workforce Security Considerations and Privacy - ISACA, section 3: “The principle of least privilege should be applied to ensure that only authorized personnel have access to the data.”
• Why Employee Privacy Matters More Than Ever - ISACA, section 3: “Privacy-first monitoring should include granular privacy controls, including: Auto-redacting personal information; Restricting access to sensitive information based on role; Masking sensitive information from view.”