A. Analyze the data inventory to map data flows

Answer DescriptionExplanation:
The best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has is to analyze the data inventory to map data flows. A data inventory is a comprehensive record of the personal data that an organization collects, stores, uses and shares. It helps to identify the sources, categories, locations, recipients and retention periods of personal data. A data flow map is a visual representation of how personal data flows within and outside an organization. It helps to identify the data transfers, processing activities, legal bases, risks and safeguards of personal data.
By analyzing the data inventory and mapping the data flows, Penny can gain a clear picture of the personal data lifecycle at Ace Space and identify any gaps or issues that need to be addressed. For example, she can determine whether Ace Space has a lawful basis for processing personal data of EU customers, whether it has adequate security measures to protect personal data from unauthorized access or loss, whether it has appropriate contracts with its vendors and cloud providers to ensure compliance with applicable laws and regulations, and whether it has mechanisms to respect the rights and preferences of its customers.
The other options are not the best way for Penny to understand the location, classification and processing purpose of the personal data Ace Space has. Auditing all vendors’ privacy practices and safeguards (B) is an important step to ensure that Ace Space’s third-party processors are complying with their contractual obligations and legal requirements, but it does not provide a comprehensive overview of Ace Space’s own personal data processing activities. Conducting a Privacy Impact Assessment (PIA) for the company © is a useful tool to assess the privacy risks and impacts of a specific project or initiative involving personal data, but it does not provide a baseline understanding of the existing personal data landscape at Ace Space. Reviewing all cloud contracts to identify the location of data servers used (D) is a relevant aspect of understanding the location of personal data, but it does not cover other aspects such as classification and processing purpose.

D. Shift attention to privacy for emerging technologies as the company begins to use them

Answer DescriptionExplanation:
Shifting attention to privacy for emerging technologies as the company begins to use them is a logical next step to help ensure a high level of protection. Emerging technologies, such as artificial intelligence, biometrics, blockchain, cloud computing, internet of things, etc., may pose new challenges and opportunities for privacy and data protection. They may involve new types, sources, uses, and flows of personal data that require different or additional safeguards and controls. They may also introduce new risks or impacts for individuals’ rights and interests that require careful assessment and mitigation. Therefore, it is important for the company to consider and address the privacy implications of emerging technologies as they adopt or integrate them into their products, services, or processes.
The other options are not as logical or effective as shifting attention to privacy for emerging technologies for ensuring a high level of protection. Brainstorming methods for developing an enhanced privacy framework may not be necessary or feasible if the company already has established new best practices for the industry. Developing a strong marketing strategy to communicate the company’s privacy practices may not be sufficient or relevant for ensuring a high level of protection, as it may not reflect the actual state or quality of the privacy program. Focusing on improving the incident response plan in preparation for any breaks in protection may be too reactive or narrow in scope, as it may not cover other aspects or dimensions of privacy and data protection that require continuous monitoring and improvement.

D. Perform a privacy readiness assessment before the deal.

Answer DescriptionExplanation:

A privacy readiness assessment is not required during a data privacy diligence process for Merger & Acquisition (M&A) deals, as it is usually done before the deal to evaluate the privacy maturity and compliance level of the target organization. The other options are required during the data privacy diligence process to ensure that the personal data of both organizations are handled in accordance with the applicable laws and regulations, as well as the expectations of the data subjects and stakeholders. References: CIPM Body of Knowledge, Domain III: Privacy Program Management Activities, Task 4: Manage data transfers.

A. Practicing data minimalism.

Answer DescriptionExplanation:
The important principle of Data Lifecycle Management (DLM) that will most likely be compromised if Anton executes his plan to limit data access to himself and Kenneth is ensuring data retrievability. Data retrievability refers to the ability to access and use data when needed for business purposes or legal obligations1 It involves maintaining the availability, integrity, and usability of data throughout its lifecycle2 However, if Anton restricts data access to only himself and Kenneth, he will create a single point of failure and a bottleneck for data retrieval. This could pose several risks and challenges for the company, such as:

• Losing data if Anton or Kenneth forgets the password or leaves the company without sharing it with others.
• Delaying data retrieval if Anton or Kenneth is unavailable or unresponsive when someone else needs the data urgently.
• Violating data protection laws or regulations that require data access by certain parties or authorities under certain circumstances.
• Reducing data quality or accuracy if Anton or Kenneth fails to update or maintain the data properly.
• Missing business opportunities or insights if Anton or Kenneth does not share the data with other relevant stakeholders or departments.

Therefore, Anton should reconsider his plan and adopt a more balanced and secure approach to data access management that follows the principle of least privilege. This means granting data access only to those who need it for their specific roles and responsibilities and revoking it when no longer needed3 He should also implement proper authentication, authorization, encryption, backup, and audit mechanisms to protect the data from unauthorized or unlawful access, use, disclosure, alteration, or destruction.

B. Data enhancement metrics.

Answer DescriptionExplanation:

Data enhancement metrics are not a type of privacy program metric because they do not measure the performance, value, or risk of the privacy program. Data enhancement metrics are related to the quality, accuracy, and completeness of the data collected and processed by the organization, which are not directly linked to the privacy program objectives. References: CIPM Body of Knowledge, Domain II: Privacy Program Governance, Section B: Establishing a Privacy Program Framework, Subsection 2: Privacy Program Metrics.

A. The number of security patches applied to company devices.

Answer DescriptionExplanation: The number of security patches applied to company devices might be the least relevant metric for a company’s privacy and governance team after a data breach. While security patches are important for preventing future breaches, they do not directly measure the impact or response of the current breach. The other metrics are more relevant for assessing how the company handled the breach, such as how it complied with the privacy rights of affected individuals, how it evaluated the privacy risks of its systems, and how it trained its employees on data awareness.

D. A responsible internal stakeholder

Answer DescriptionExplanation: This answer is the key factor that lays the foundation for all other elements of a privacy program, as it can help to establish leadership, accountability and support for the privacy program within the organization. A responsible internal stakeholder is a person or group who has authority, influence or interest in the organization’s data processing activities, such as senior management, board members, business units or departments. A responsible internal stakeholder can help to define and communicate the organization’s vision, mission and goals for privacy protection, allocate resources and budget for the privacy program, approve and endorse privacy policies and procedures, monitor and evaluate privacy program performance and compliance, and resolve any issues or conflicts that may arise from data processing activities.

C. Statistical.

Answer DescriptionExplanation:

This answer is the best form of trend analysis that Incipia Corporation should use to analyze the effectiveness of the training over the next six months, as it can provide a quantitative and objective way to measure and compare the results and outcomes of the training against predefined criteria or indicators. Statistical trend analysis is a method that involves collecting, analyzing and presenting data using statistical tools and techniques, such as charts, graphs, tables or formulas.

Statistical trend analysis can help to identify patterns, changes or correlations in the data over time, as well as to evaluate the performance and impact of the training on the organization’s privacy program and objectives. References: IAPP CIPM Study Guide, page 901; ISO/IEC 27002:2013, section 18.1.3