Question 11

Under the Fair and Accurate Credit Transactions Act (FACTA), what is the most appropriate action for a car dealer holding a paper folder of customer credit reports?
  • Question 12

    The Cable Communications Policy Act of 1984 requires which activity?
  • Question 13

    SCENARIO
    Please use the following to answer the next question:
    Brady is a computer programmer based in New Zealand who has been running his own business for two years.
    Brady's business provides a low-cost suite of services to customers throughout the European Economic Area (EEA). The services are targeted towards new and aspiring small business owners. Brady's company, called Brady Box, provides web page design services, a Social Networking Service (SNS) and consulting services that help people manage their own online stores.
    Unfortunately, Brady has been receiving some complaints. A customer named Anna recently uploaded her plans for a new product onto Brady Box's chat area, which is open to public viewing. Although she realized her mistake two weeks later and removed the document, Anna is holding Brady Box responsible for not noticing the error through regular monitoring of the website. Brady believes he should not be held liable.
    Another customer, Felipe, was alarmed to discover that his personal information was transferred to a third- party contractor called Hermes Designs and worries that sensitive information regarding his business plans may be misused. Brady does not believe he violated European privacy rules. He provides a privacy notice to all of his customers explicitly stating that personal data may be transferred to specific third parties in fulfillment of a requested service. Felipe says he read the privacy notice but that it was long and complicated Brady continues to insist that Felipe has no need to be concerned, as he can personally vouch for the integrity of Hermes Designs. In fact, Hermes Designs has taken the initiative to create sample customized banner advertisements for customers like Felipe. Brady is happy to provide a link to the example banner ads, now posted on the Hermes Designs webpage. Hermes Designs plans on following up with direct marketing to these customers.
    Brady was surprised when another customer, Serge, expressed his dismay that a quotation by him is being used within a graphic collage on Brady Box's home webpage. The quotation is attributed to Serge by first and last name. Brady, however, was not worried about any sort of litigation. He wrote back to Serge to let him know that he found the quotation within Brady Box's Social Networking Service (SNS), as Serge himself had posted the quotation. In his response, Brady did offer to remove the quotation as a courtesy.
    Despite some customer complaints, Brady's business is flourishing. He even supplements his income through online behavioral advertising (OBA) via a third-party ad network with whom he has set clearly defined roles.
    Brady is pleased that, although some customers are not explicitly aware of the OBA, the advertisements contain useful products and services.
    Based on the scenario, what is the main reason that Brady should be concerned with Hermes Designs' handling of customer personal data?
  • Question 14

    A covered entity suffers a ransomware attack that affects the personal health information (PHI) of more than 500 individuals. According to Federal law under HIPAA, which of the following would the covered entity NOT have to report the breach to?
  • Question 15

    SCENARIO
    Tom looked forward to starting his new position with a U.S -based automobile leasing company (New Company), now operating in 32 states. New Company was recently formed through the merger of two prominent players, one from the eastern region (East Company) and one from the western region (West Company). Tom, a Certified Information Privacy Technologist (CIPT), is New Company's first Information Privacy and Security Officer. He met today with Dick from East Company, and Harry, from West Company.
    Dick and Harry are veteran senior information privacy and security professionals at their respective companies, and continue to lead the east and west divisions of New Company. The purpose of the meeting was to conduct a SWOT (strengths/weaknesses/opportunities/threats) analysis for New Company. Their SWOT analysis conclusions are summarized below.
    Dick was enthusiastic about an opportunity for the New Company to reduce costs and increase computing power and flexibility through cloud services. East Company had been contemplating moving to the cloud, but West Company already had a vendor that was providing it with software-as-a-service (SaaS). Dick was looking forward to extending this service to the eastern region. Harry noted that this was a threat as well, because West Company had to rely on the third party to protect its data.
    Tom mentioned that neither of the legacy companies had sufficient data storage space to meet the projected growth of New Company, which he saw as a weakness. Tom stated that one of the team's first projects would be to construct a consolidated New Company data warehouse. Tom would personally lead this project and would be held accountable if information was modified during transmission to or during storage in the new data warehouse.
    Tom, Dick and Harry agreed that employee network access could be considered both a strength and a weakness. East Company and West Company had strong performance records in this regard; both had robust network access controls that were working as designed. However, during a projected year-long transition period, New Company employees would need to be able to connect to a New Company network while retaining access to the East Company and West Company networks.
    Which statement is correct about addressing New Company stakeholders' expectations for privacy?
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