Free CDPSE Isaca Updates

HTTP cookies are the standard mechanism used by websites to recognize returning visitors by storing a small piece of metadata on the user’s browser. Flash cookies (D) and supercookies (A) exist but are not as common or compliant. Server cookies (C) are not a distinct browser-side identifier. The CDPSE emphasizes cookies as central to tracking, profiling, and consent requirements.

“Cookies… small data stored on a browser to recognize repeat visits and enable tracking.”

The first thing to do when a data collection process is deemed to be a high-level risk is to conduct a privacy impact assessment (PIA). A PIA is a systematic process that identifies and evaluates the potential effects of personal data processing operations on the privacy of individuals and the organization. A PIA helps to identify privacy risks and mitigation strategies at an early stage of the data collection process and ensures compliance with legal and regulatory requirements. A PIA also helps to demonstrate accountability and transparency to stakeholders and data subjects regarding how their personal data are collected, used, shared, stored, or deleted.

Performing a business impact analysis (BIA), implementing remediation actions to mitigate privacy risk, or creating a system of records notice (SORN) are also important steps for managing privacy risk, but they are not the first thing to do. Performing a BIA is a process of analyzing the potential impacts of disruptive events on the organization’s critical functions, processes, resources, or objectives. A BIA helps to determine the recovery priorities, strategies, and objectives for the organization in case of a disaster or crisis. Implementing remediation actions is a process of applying corrective or preventive measures to reduce or eliminate the privacy risks identified by the PIA or other methods. Remediation actions may include technical, organizational, or legal solutions, such as encryption, access control, consent management, or contractual clauses. Creating a SORN is a process of publishing a public notice that describes the existence and purpose of a system of records that contains personal data under the control of a federal agency. A SORN helps to inform the public about how their personal data are collected and maintained by the agency and what rights they have regarding their data.

Height, weight, and activities are the most legitimate information to collect for business reasons in this situation, as they are directly related to the purpose and functionality of a wellness smartwatch application that aims to monitor and improve the health and fitness of its users. Collecting height, weight, and activities would also comply with the data minimization principle that requires limiting the collection, storage and processing of personal data to what is necessary and relevant for the intended purposes. The other options are not legitimate information to collect for business reasons in this situation, as they are not related to the purpose and functionality of a wellness smartwatch application and may violate the privacy rights and preferences of its users. Collecting sleep schedule and calorie intake may be useful for some users who want to track their sleep quality and nutrition intake, but they are not essential for a wellness smartwatch application and may require additional consent or justification from the users. Collecting education and profession may be irrelevant for a wellness smartwatch application and may be used for other purposes, such as marketing or profiling, without the consent or knowledge of the users. Collecting race, age, and gender may be sensitive for some users who do not want to disclose their personal characteristics or identity, and may require additional safeguards or measures to protect their privacy1, p. 75-76 References: 1: CDPSE Review Manual (Digital Version)

Pseudonymization is a technique that replaces direct identifiers in a data set with pseudonyms or artificial identifiers that do not reveal the identity of the data subjects. Pseudonymization is the best method to protect customers’ personal data that is forwarded to a central system for analysis, as it reduces the linkability of the data set with the original identity of the customers and thus enhances the privacy and security of the data. Pseudonymization also preserves some characteristics or patterns of the original data that can be used for analysis or research purposes, without compromising the accuracy or quality of the results. The other options are not as effective as pseudonymization in protecting customers’ personal data that is forwarded to a central system for analysis. Deletion is a technique that removes or destroys data from a storage device or media to prevent unauthorized access or recovery of the data, but it does not allow for any analysis or research purposes. Encryption is a technique that transforms plain text data into cipher text using an algorithm and a key, making it unreadable by unauthorized parties, but it does not reduce the linkability of the data set with the original identity of the customers and may require additional security measures to protect the encryption keys or certificates. Anonymization is a technique that removes or modifies all identifiers in a data set to prevent or limit the identification of the data subjects, but it may affect the accuracy or quality of the analysis or research results, as some characteristics or patterns of the original data may be lost or distorted1, p. 74-75 References: 1: CDPSE Review Manual (Digital Version)