IAPP CIPM Practice Test : Free Online Preparation

lost.

When you contact the contracts officer, he tells you that he received a letter in the mail from a vendor stating

that the vendor improperly shared information about your customers. He called the vendor and confirmed that

your company recently surveyed exactly 2000 individuals about their most recent healthcare experience and

sent those surveys to the vendor to transcribe it into a database, but the vendor forgot to encrypt the database

as promised in the contract. As a result, the vendor has lost control of the data.

The vendor is extremely apologetic and offers to take responsibility for sending out the notifications. They tell

you they set aside 2000 stamped postcards because that should reduce the time it takes to get the notice in the

mail. One side is limited to their logo, but the other side is blank and they will accept whatever you want to write.

You put their offer on hold and begin to develop the text around the space constraints. You are content to let

the vendor’s logo be associated with the notification.

The notification explains that your company recently hired a vendor to store information about their most recent

experience at St. Sebastian Hospital’s Clinic for Infectious Diseases. The vendor did not encrypt the information

and no longer has control of it. All 2000 affected individuals are invited to sign-up for email notifications about

their information. They simply need to go to your company’s website and watch a quick advertisement, then

provide their name, email address, and month and year of birth.

You email the incident-response council for their buy-in before 9 a.m. If anything goes wrong in this situation,

you want to diffuse the blame across your colleagues. Over the next eight hours, everyone emails their

comments back and forth. The consultant who leads the incident-response team notes that it is his first day with

the company, but he has been in other industries for 45 years and will do his best. One of the three lawyers on

the council causes the conversation to veer off course, but it eventually gets back on track. At the end of the

day, they vote to proceed with the notification you wrote and use the vendor’s postcards.

Shortly after the vendor mails the postcards, you learn the data was on a server that was stolen, and make the

decision to have your company offer credit monitoring services. A quick internet search finds a credit monitoring

company with a convincing name: Credit Under Lock and Key (CRUDLOK). Your sales rep has never handled

a contract for 2000 people, but develops a proposal in about a day which says CRUDLOK will:

1. Send an enrollment invitation to everyone the day after the contract is signed.

2. Enroll someone with just their first name and the last-4 of their national identifier.

3. Monitor each enrollee’s credit for two years from the date of enrollment.

4. Send a monthly email with their credit rating and offers for credit-related services at market rates.

5. Charge your company 20% of the cost of any credit restoration.

You execute the contract and the enrollment invitations are emailed to the 2000 individuals. Three days later

you sit down and document all that went well and all that could have gone better. You put it in a file to reference

the next time an incident occurs.

Regarding the credit monitoring, which of the following would be the greatest concern?

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