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IAPP Exam CIPM Topic 6 Question 68 Discussion

Actual exam question for IAPP's CIPM exam
Question #: 68
Topic #: 6
[All CIPM Questions]

Your company wants to convert paper records that contain customer personal information into electronic form, upload the records into a new third-party marketing tool and then merge the customer personal information in the marketing tool with information from other applications.

As the Privacy Officer, which of the following should you complete to effectively make these changes?

Show Suggested Answer Hide Answer
Suggested Answer: D

A Privacy Impact Assessment (PIA) is a process that helps an organization identify and evaluate the potential privacy risks and impacts of a new or existing project, program, system, or service that involves the collection, use, disclosure, or retention of personal information. A PIA also helps an organization identify and implement appropriate measures to mitigate or eliminate those risks and impacts, and ensure compliance with applicable privacy laws, regulations, and standards. A PIA should be completed to effectively make changes that involve customer personal information, such as converting paper records into electronic form, uploading the records into a new third-party marketing tool, and merging the customer personal information in the marketing tool with information from other applications. A PIA can help an organization assess the necessity, proportionality, and legality of the proposed changes, as well as the potential privacy risks to the customers and the organization, such as unauthorized access, disclosure, modification, or loss of personal information, identity theft, fraud, reputational damage, or legal liability. A PIA can also help an organization implement appropriate measures to mitigate or eliminate those risks, such as data minimization, encryption, anonymization, pseudonymization, consent management, access control, security safeguards, contractual clauses, data protection impact assessments (DPIAs), data subject rights, breach notification procedures, and privacy policies.


CIPM Body of Knowledge (2021), Domain IV: Privacy Program Operational Life Cycle, Section C: Monitoring and Managing Program Performance Subsection 1: Privacy Impact Assessments1

CIPM Study Guide (2021), Chapter 9: Monitoring and Managing Program Performance Section 9.1: Privacy Impact Assessments2

CIPM Textbook (2019), Chapter 9: Monitoring and Managing Program Performance Section 9.1: Privacy Impact Assessments3

CIPM Practice Exam (2021), Question 1464

Contribute your Thoughts:

Filiberto
2 months ago
D) A Privacy Impact Assessment (PIA) is the obvious choice here. Unless you want your company to end up on the front page of the newspaper for all the wrong reasons. Hey, at least you'd get some publicity, right?
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Ryan
2 months ago
Agreed, let's not take any chances with customer personal information.
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Avery
2 months ago
Avery is right, we need to make sure we're covering all our bases.
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Sylvia
2 months ago
D) A Privacy Impact Assessment (PIA) is definitely the way to go.
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Franchesca
2 months ago
A PIA is definitely the way to go. But I hope the new marketing tool has better privacy features than the old paper records. Remember the 'Pigeon Post Debacle' of '95? Yikes!
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Giovanna
2 months ago
Hmm, I was leaning towards C) A Privacy Threshold Analysis (PTA). Doesn't that help determine if a full PIA is needed? Gotta cover all the bases, you know.
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Lilli
2 months ago
I agree with Jamie. A PIA is the way to go here. Can't just start uploading customer data willy-nilly without understanding the potential privacy implications.
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Rosenda
1 months ago
Completing a Privacy Impact Assessment (PIA) is crucial before making these changes.
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Stephaine
1 months ago
Agreed, a PIA will help identify and mitigate any privacy risks.
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Ernie
1 months ago
I think a Privacy Impact Assessment (PIA) is the best option.
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Johana
2 months ago
A PIA is definitely necessary in this situation.
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Jamie
3 months ago
I think the correct answer is D) A Privacy Impact Assessment (PIA). Converting paper records to electronic form and sharing personal information with a third-party tool definitely requires a thorough assessment of the privacy risks.
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Kristine
2 months ago
After completing the PIA and Personal Data Inventory, we can then determine if a Privacy Threshold Analysis (PTA) is needed for further assessment.
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Bettina
2 months ago
I think we should also consider completing a Personal Data Inventory to understand what customer personal information we have.
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Miesha
2 months ago
I agree, a Privacy Impact Assessment (PIA) is necessary to assess the privacy risks involved in this process.
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Argelia
3 months ago
I think both a PIA and a Personal Data Inventory would be necessary to ensure we are compliant and protect customer data.
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Kris
3 months ago
But wouldn't a Personal Data Inventory also be important to understand what customer information we have?
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Callie
4 months ago
I agree with Lucina, a PIA would help us identify and mitigate any privacy risks.
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Lucina
4 months ago
I think we should complete a Privacy Impact Assessment (PIA) for this.
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