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DSCI DCPLA Exam Syllabus Topics:
| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Privacy Assessment and Audit Practices | 15% | - Reporting and follow-up
|
| Topic 2: Privacy Operations and Lifecycle Management | 15% | - Data lifecycle controls
|
| Topic 3: Privacy Risk Management | 15% | - Risk treatment and control implementation
|
| Topic 4: Privacy Regulatory Compliance | 20% | - Compliance assessment and audit
|
| Topic 5: Privacy Frameworks and Standards | 20% | - DSCI Privacy Framework (DPF)
|
| Topic 6: Privacy Governance and Organization | 15% | - Privacy roles, responsibilities and structure
|
DSCI Certified Privacy Lead Assessor DCPLA certification Sample Questions:
From the following list, identify the technology aspects that are specially designed for upholding privacy:
I) Data minimization
II) Intrusion prevention system
III) Data scrambling
IV) Data loss prevention
V) Data portability
VI) Data obfuscation
VII) Data encryption
VIII) Data mirroring
- A. Only II, V, VI, VII and VIII
- B. Only I, III, IV, VI and VII
- C. Only I, III, V, VII and VIII
- D. Only I, II, III, VII and VIII
Correct Answer: B 🗳️
Explanation: Only visible for VCEDumps members. You can sign-up / login (it's free).
Classify the following scenario as major or minor non-conformity.
"The organization defined information access and usage policy and rolled it out across the organization No formal exercise, however, was conducted to prepare the policy During implementation, certain discrepancies came out and these were addressed through appropriate policy revisions though this created a lot of hue and cry in the organization and the policy was criticized for adversely affecting productivity But with appropriate revisions and passage of time, the policy has been accepted In a recently conducted external audit one incident has come to light wherein the usage and access policy has been violated by an employee twice As per the auditor this incident should have been identified by the organization In its explanation to the auditor the management informed that appropriate access and usage monitoring mechanisms have been put in place but admitted that there may have been some lapses".
- A. Minor
- B. None of the above
- C. Both Major & Minor
- D. Major
Correct Answer: A 🗳️
There are several privacy incidents reported in an organization. The organization plans to analyze and learn from these incidents. Which privacy practice will the organization have to implement for the same?
- A. Information usage and access
- B. Privacy contract management
- C. Privacy awareness and training
- D. Privacy monitoring and incident management
Correct Answer: D 🗳️
Explanation: Only visible for VCEDumps members. You can sign-up / login (it's free).
Which of the following is not an appropriate privacy principle?
L Collection limitation
ii Collection limitation
in Notice
iv. Consent
v Access & correction
VI. Data usage
- A. Collection limitation
- B. Data usage
- C. Access & Correction
- D. Notice
Correct Answer: D 🗳️
RCI and PCM
The Digital Personal Data protection Act 2023 has been passed recently. The Act shall be supported by subordinate Rules for various sections that will gradually bring more clarity into various aspects of the law.
First set of Rules are yet to be formulated and notified. A public sector bank has identified that it collects and processes personal data in physical documents and electronic form. The bank intends to assess its existing compliance level and proactively undertake an exercise to ensure compliance. Since this is the first time the bank is attempting to comply with a comprehensive privacy law, it has hired a legal expert in Privacy law to assist with initial assessment and compliance activities. As part of the initial visibility exercise the consultant identified that the bank collects and generates a significant amount of personal data in physical and digital form. The data may be upto 200 million customers' data. It is identified that customer onboarding is also done through various business correspondents in the field who collect and process personal data in physical and digital form on behalf of the bank for the purpose of opening bank accounts and this data is shared with the bank through various channels. There are upto 10 business correspondent companies that have been appointed by the bank across the country for such onboarding. These companies further appoint individual contractors on the field to face the customers. The legal consultant also identified that there are a huge number of employees and contractors engaged by the bank whose personal data is being collected and processed by the bank for HR purposes including biometric based attendance. While the intent of initial assessment was the new Act, the legal consultant has also identified that the Bank collects Aadhaar numbers (voluntary submission) from customers and employees and may be subject to Aadhaar Act compliance. It also came as a surprise that the bank wasn't aware of the data breach reporting mandate by one of the regulatory bodies under the Information Technology Act 2000 and that it was a criminal offense. The Bank generally outsources all non-core activities such as call centers which are handled by an Indian BPO company and document warehousing which is handled by another company. The Bank has also moved many of its applications to a known cloud provider as part of its digital strategy and there may be data transfer aspects associated with the same. On review of various contracts with third parties it was identified that the bank has signed standard terms of the cloud provider and has signed contracts with third parties which were in standard format of the third parties. Data protection obligations are not clear or available in these contracts. Bank leadership has been of the opinion that even the third parties should comply with the laws and robust contracts on legal compliance may not be needed. The legal consultant is not just expected to help identify gaps. assist in fixing the gaps but also to help implement controls and processes to continuously comply with evolving Rules under the new Act and also manage data protection with various third parties that may be appointed in the future.
(Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion) Introduction and Background XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than
500 clients across industry verticals - BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.
The company is witnessing phenomenal growth in the BPM services over last few years including Finance and Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects. The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).
To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens.
The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.
Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.
Why did the Bank not identify till date that they were subject to various other laws related to personal data?
What processes and controls can the legal consultant help the bank with which would help them avoid such gaps with respect to future regulations and rules issued under the new Act? Please answer with respect to the RCI practice area. (upto 250 words)
Correct Answer:
See the answer in explanation below.
Explanation:
The bank has been in a hectic expansion mode and has never been subject to the regulations concerning to the data privacy. This is a huge bank with over 200 million customers, the business operations sperad across many geographies and multiple operating business corrospondents enganed on behalf of the bank. Thus the bank has till date not identified various other laws related with the data privacy.
The consultant has helped bank implement the following processes -
1. Document the overall business organizations, various geographical presence, various business processes, business partners.
2. Identify all related data privacy laws and regulations that pertains to the various business processes, in each geography and map the regulatory requirements with each personal information being collected/processed.
3. Define the control requirements for each and every piece of the personal information based on the the geography/jurisdiction in which it is being processed.
4. Standardize the contractual clauses with the various business associates with respect to the processing og the personal information. Assign the accountability of the adherence by way of contract amendment. These clauses needs to be included in the new contract as and when they are created.
5. Implement a organization framework comprising the legal, compliance, regulatory and business teams to establish the method by which the new regulations will be tracked and the new controls be incorporated in the overall process.
6. Implement the method to assess companies' compliance against these controls and implement the remediation methods if any non-compliance is identified.
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