Isaca Certification CDPSE Reddit Questions

In GDPR parlance, organizations that use third-party service providers are often, but not always, considered data controllers, which are entities that determine the purposes and means of the processing of personal data, which can include directing third parties to process personal data on their behalf. The third parties that process data for data controllers are known as data processors.

The best way to protect personal data in the custody of a third party is to include requirements to comply with the organization’s privacy policies in the contract. This means that the organization should specify the terms and conditions of data processing, such as the purpose, scope, duration, and security measures, and ensure that they are consistent with the organization’s privacy policies and applicable privacy regulations. The contract should also define the roles and responsibilities of both parties, such as data controller and data processor, and establish mechanisms for monitoring, reporting, auditing, and resolving any issues or incidents related to data privacy. References: : CDPSE Review Manual (Digital Version), page 41

A thin client remote desktop protocol (RDP) is the most effective remote access model for reducing the likelihood of attacks originating from connecting devices, because it minimizes the amount of data and processing that occurs on the remote device. A thin client RDP only sends keyboard, mouse and display information between the remote device and the server, while the actual processing and storage of data happens on the server. This reduces the exposure of sensitive data and applications to potential attackers who may compromise the remote device.

References:

• CDPSE Review Manual, Chapter 2 – Privacy Architecture, Section 2.3 – Privacy Architecture Implementation1.
• CDPSE Certified Data Privacy Solutions Engineer All-in-One Exam Guide, Chapter 2 – Privacy Architecture, Section 2.4 – Remote Access2.

A data loss prevention (DLP) tool is a software solution that monitors, detects and prevents the unauthorized transmission or leakage of sensitive data, such as personal data, from an organization’s network or devices. A DLP tool can help to ensure the effectiveness of a policy requiring the encryption of personal data if transmitted through email, by applying the following controls:

• Scanning the content and attachments of outgoing emails for personal data, such as names, email addresses, biometric data, IP addresses, etc.
• Blocking or quarantining emails that contain unencrypted personal data, and alerting the sender and/or the administrator of the policy violation.
• Encrypting personal data automatically before sending them through email, using encryption standards and algorithms that are compliant with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA).
• Generating audit logs and reports of email activities and incidents involving personal data, and providing visibility and accountability for policy compliance.

The other options are less effective or irrelevant to ensure the effectiveness of the policy. Providing periodic user awareness training on data encryption is a good practice, but it does not guarantee that users will follow the policy or know how to encrypt personal data properly. Conducting regular control self-assessments (CSAs) is a useful method to evaluate the design and operation of the policy, but it does not prevent or detect policy violations in real time. Enforcing annual attestation to policy compliance is a formal way to demonstrate user commitment to the policy, but it does not verify or measure the actual level of compliance.

References:

• The Complexity Conundrum: Simplifying Data Security - ISACA, section 3: “Data loss prevention (DLP) solutions can help prevent unauthorized access to sensitive information by monitoring network traffic for specific keywords or patterns.”
• Guide to Securing Personal Data in Electronic Medium, section 3.2: “Organisations should consider implementing DLP solutions to prevent unauthorised disclosure of personal data via email.”
• Encryption in the Hands of End Users - ISACA, section 2: “A key goal of encryption is to protect the file even when direct access is possible or the transfer is intercepted.”

A data use policy is a document that defines the rules and guidelines for how personal data are collected, used, stored, shared and deleted by an organization. It is an important part of data governance and compliance, as it helps to ensure that personal data are handled in a lawful, fair and transparent manner, respecting the rights and preferences of data subjects. A data use policy should include the requirements for collecting and using personal data, such as the legal basis, the purpose, the scope, the consent, the data minimization, the accuracy, the security and the accountability. These requirements help to establish the legitimacy and necessity of data processing activities, and to prevent unauthorized or excessive use of personal data.

References:

• ISACA Privacy Notice & Usage Disclosures, section 2.1: “We collect Personal Information from you when you provide it to us directly or through a third party who has assured us that they have obtained your consent.”
• Chapter Privacy Policy - Singapore Chapter - ISACA, section 2: “We will collect your personal data in accordance with the PDPA either directly from you or your authorized representatives, and/or through our third party service providers.”
• Data Minimization—A Practical Approach - ISACA, section 2: “Enterprises may only collect as much data as are necessary for the purposes defined at the time of collection, which may also be set out in a privacy notice (sometimes referred to as a privacy statement, a fair processing statement or a privacy policy).”
• Establishing Enterprise Roles for Data Protection - ISACA, section 3: “Data governance is typically implemented in organizations through policies, guidelines, tools and access controls.”