Domain 4: Protecting Personal Data Flashcards

Master how to apply controls, privacy-by-design, and security practices to protect data. (73 cards)

1
Q

List the 7 principles of Privacy by Design.

A
  1. Respect for users
  2. Proactive/preventative
  3. Default setting
  4. Embedded into design
  5. Positive sum
  6. End-to-end security
  7. Transparent
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2
Q

List the 7 GDPR principles.

A
  • Lawfulness, fairness, and transparency
  • Purpose limitation
  • Data minimization
  • Accuracy
  • Storage limitation
  • Integrity and confidentiality
  • Accountability
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3
Q

What is a Data Flow Diagram?

(DFD)

A

A visual representation of how data flows through a system or process.

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4
Q

What elements should be included in a DFD?

A
  • Actors
  • Location
  • Data flow
  • Risks
  • Threats
  • Vulnerabilities
  • Controls
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5
Q

Give examples of modern risks to information security.

A
  • Cloud-based threats
  • Insider threat
  • Telework
  • Phishing
  • AI deepfakes
  • IoT
  • Ransomware
  • Living off the Land (LotL) attacks
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6
Q

What are the types of controls based on purpose?

A
  • Preventative
  • Detective
  • Corrective
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7
Q

What is an ISMS?

A
  • Information Security Management System
  • Framework to protect sensitive data using policies, procedures, and controls
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8
Q

How do InfoSec and privacy overlap?

A

They share goals such as:

  • Accuracy
  • Integrity
  • Authorized access
  • Accountability
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9
Q

How do InfoSec and privacy diverge?

A

InfoSec:

  • Lacks FIPs
  • Doesn’t always apply confidentiality to PII
  • Can misuse PETs
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10
Q

What is data classification?

A

Organizing data by content, sensitivity, and importance to assess risk and apply mitigations.

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11
Q

What are common InfoSec data classifications?

A
  • Public
  • Confidential
  • Highly Confidential
  • Restricted
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12
Q

What are privacy data types?

A
  • Personal
  • Sensitive
  • Nonpersonal
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13
Q

Describe the identifiability spectrum.

A
  • Personal (identifiable)
  • De-identified (pseudonymous)
  • Anonymized (unlinkable)
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14
Q

Why is context important in data classification?

A

Same data may be public in one context and restricted in another.

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15
Q

What are key partnership areas between InfoSec and privacy?

A
  • Breach response
  • Standards
  • Data mapping
  • Due diligence
  • Education
  • PIAs
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16
Q

What are principles for InfoSec-privacy alignment?

A
  • Partner
  • Leverage existing docs
  • Raise awareness
  • Prioritize issues
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17
Q

What is the purpose of access control?

A

To restrict resource availability and regulate who can access system resources.

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18
Q

What are the main components of access control?

A
  • Authentication
  • Authorization
  • Audit
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19
Q

What does authentication verify?

A

It verifies the user’s identity.

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20
Q

What happens after authentication?

A

Authorization is granted to access specific resources.

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21
Q

What is audit in access control?

A

Monitoring and recording user activities.

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22
Q

What does RBAC stand for?

A

Role-Based Access Control

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23
Q

What is the principle of segregation of duties?

A

Ensures no single person controls all aspects of a process to prevent fraud and error.

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24
Q

What is the least privilege principle?

A

Users get only the access necessary to perform their job.

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25
What is the **need-to-know** principle?
Access is **restricted** to only those who **need it for official duties**.
26
What is **Identity Access Management** (IAM)?
A framework to **manage digital identities** and regulate user access.
27
List IAM guidelines.
* Clean-desk policy * Logical access * Unique IDs * Password management * Access audits * User training
28
What are the **4 types** of **administrative** policy controls?
* Laws and regulations * Self-regulation * Industry practice * Corporate
29
What is an example of a **law and regulation** control?
* GDPR requires deletion upon request * Control via metadata tagging and deletion mechanisms
30
What is **self-regulation** in administrative controls?
Organizations **follow industry standards** like PCI-DSS to protect data. ## Footnote Example: PCI-DSS requires cardholder data encryption; control is AES 256
31
What is an **industry practice** control?
* Following GAPP * Requiring consent through privacy notices and opt-in mechanisms
32
Give an **example** of a **corporate control**.
Apple's **App Tracking Transparency** feature based on privacy as a human right.
33
What is the purpose of **obfuscation** in technical controls?
To **render data unintelligible** and protect it from unauthorized access. ## Footnote Examples: pseudonymizing data; showing only last 4 digits of SSN/account number.
34
What are **security measures** in **technical controls**?
**Encryption** and **access controls** to prevent unauthorized access.
35
What are **Privacy-Enhancing Technologies**? | (PETs)
Tools/techniques to protect PII by minimizing its use and exposure.
36
What is the **difference** between a **privacy policy** and a **privacy notice**?
* **Policy** is internal (corporate accountability) * **Notice** is external (public education)
37
What is a **privacy policy**?
* A **high-level document** explaining how an organization handles PII * Supports **standards** and **procedures**
38
What are the **goals** of a privacy policy?
* Outline strategy * Direct stakeholders * Guide resource allocation
39
What are **characteristics** of an effective privacy policy?
* Plain language * Comprehensive * Action-oriented * Measurable
40
What is the **purpose section** of a privacy policy?
Explains the reason for existence, program goals, and alignment with business objectives.
41
What does the **scope section** of a privacy policy define?
Specifies **the data** the policy applies to.
42
What does the **applicability section** of a privacy policy define?
Identifies **who** the policy applies to.
43
What is covered in the **roles and responsibilities** section?
Defines **duties for each role** and determines **accountability**. ## Footnote e.g., CPO, vendors
44
What does the **compliance section** outline?
Lists legal, regulatory, and policy requirements, monitoring, and enforcement authority.
45
What is the purpose of the **penalties for non-compliance section**?
Explains **penalties** and monitors them across the industry.
46
**Why** is it important to **communicate** the privacy policy?
To ensure: * Awareness * Local communication by function reps * Privacy education
47
What are the **key elements** of an **internal communication plan**?
* Purpose * Audience * Existing channels * Medium * Office hours * Buy-in * Compliance motivation
48
What are **common mediums** for internal communication?
* In-person * Virtual * Hybrid * Pre-recorded sessions
49
What are some **budget considerations** for privacy policy implementation?
* New tech/services * Process changes * Administrative tasks (e.g., drafting, publishing, auditing)
50
What causes **administrative burden** in policy drafting?
* Drafting * Reviewing * Publishing * Communicating policy * Audit participation
51
What is the purpose of **privacy-supporting policies**?
To **integrate** and **align** organizational policies with privacy principles.
52
What is an **Acceptable Use Policy**? | (AUP)
A policy that **outlines rules and expectations** for system and resource access and use.
53
What are **key AUP considerations**?
* User privacy * Legal protections * Resource limitations * Compliance with CIA and policies
54
What are the **objectives** of **InfoSec policies**?
* Protect CIA * Ensure compliance * Support data governance
55
What are typical **InfoSec** policy considerations?
* Password management * Bring Your Own Device (BYOD) * Software usage * Internet access * Control configurations * Logging
56
What is **acquisition**?
* Process of obtaining goods, services, or assets * Includes life cycle from planning to disposal
57
What is **procurement**?
* Subset of acquisition * Sourcing and purchasing from external suppliers
58
What are vendor **policy considerations**?
* Equal standards as employees * Identify obligations * Assess risk * Include in contract * Audit
59
What should a **vendor policy** include?
* Procurement/employment lifecycle * Data mapping * Risk mitigation * Certifications
60
What are **vendor contract** basics?
* Must meet legal, regulatory, policy needs * Involve legal and SME input
61
What are **specifics** to include in **vendor contracts**?
* Data backups * Metrics * Permissions * Controls * Audit rights * Data disposal * Breach plan
62
What is **vendor risk management**?
* Also known as third-party risk management * Ensures compliance and mitigates risks
63
What are the **key compliance areas** in vendor risk management?
* Contracts * Legal * Regulatory * Policy requirements * Financial obligations
64
What are the **main objectives** of a **Vendor Management Program**? | (VMP)
* Ensure accountability * Consistency * Service delivery * Privacy/security * Prevent data misuse
65
How should organizations **manage** cloud-based vendors?
* Use the same risk management approach * Apply to public, private, and hybrid clouds
66
What is the **role** of **Human Resources** (HR)?
Manages **workforce issues**. ## Footnote E.g., hiring, training, benefits, compliance, and conflict resolution.
67
What is **Human Resources Management**? | (HRM)
A **strategic approach** to **managing workforce**, including planning and decision-making.
68
What is the **goal** of HR policies in privacy?
To ensure protection of PII through data access, handling, and monitoring controls.
69
Why is a **data disposition policy** important?
* Supports data minimization * Reduces expense, liability, and need for protection and storage
70
What are **key factors** in policy development for **data retention**?
Identify: * What data * Where it is * How it's stored * Why it's retained
71
What should **guide** data retention decisions?
* Legal, regulatory, industry requirements * Business impact
72
**Why** collaborate **with IT** in policy development?
* Ensure technical feasibility * Address cybersecurity retention needs
73
What are **best practices** for implementing a retention policy?
* Communicate via training * Integrate into workflows * Align with policies * Consider jurisdictional needs