Information Management from a U.S. Perspective Flashcards
18-22 questions
Define:
information management
establishing, implementing and monitoring the organization’s privacy program under the direction of a senior person in the organization
duties of a chief privacy officer
developing and implementing policies related to data processing and properly handling of personal information
duties of a data protection officer
- ensures organization’s processing and handling of personal info is in compliance with legal privacy requirements
- cannot be directly involved with decision-making regarding data processing activities
duties of a privacy engineer
works to ensure that compliance with legal requirements has occurred through the technical processes of the organization
duties of a privacy manager
responsible for development, maintenance and enforcement of privacy policies and procedures within an organization
duties of a privacy analyst
manages legal and operational risks related to personal information held by the organization
what are the stages of a data life cycle?
- data creation
- data storage
- data sharing and usage
- data archival
- data deletion
Define:
data inventory
undertake an inventory of the PI it collects, stores, uses or discloses within the organization and to outside entities
Define:
data classification
- classify data according to its level of sensitivity
- defines clearance of individuals who can access or handle that data, as well as the baseline level of protection appropriate for that data
Define:
data flow mapping
examine and document data flows
top-down vs. bottom-up data flow mapping
- top-down: starts with record of processing activities (RoPA) which is required under GDPR
- RoPA process involves documenting the purpose for processing the PI; parties to whom any PI was disclosed; retention period for PI; and details about the safeguards in place for PI
- bottom-up: understanding data assets; data inventory and classification; delineating data processes (RoPA); documenting data lineage
privacy program should…
- demonstrate effective and auditable framework to enable compliance with applicable privacy laws and regulations
- promote trust and confidence in the organization’s handling of personal data
- respond effectively to requests by consumers
- address privacy and security breaches
- continually monitor and improve the maturity of the privacy program
privacy mission statement
describes core function of privacy within the org
How to ensure appropriate metrics for privacy program framework?
- identifying intended audience for metrics
- defining reporting sources
- defining privacy metrics for oversight and governance
- identifying systems/application collection points
What are the four stages of privacy operatonal life cycle?
- assess
- protect
- sustain
- respond
assess
- document baseline of privacy program
- evaluate processors and third parties
- identify operational risks
- document the assessment
protect
- review access controls and technical controls
- review incident response plan
- integrate privacy requirements into functional areas of the organization
sustain
- monitor and audit compliance with privacy policies
- monitor regulatory changes
- hold employee, management and contractor trainings
respond
- consumer requests
- address privacy incidents
Define:
privacy policy
high-level document that helps an organization meet policy goals contained within an org’s privacy vision or mission statement
typical components of a privacy policy
- purpose
- scope
- applicability
- roles and responsibilities
- compliance
- penalties and sanctions for noncompliance
revision to privacy policy
- according to FTC, companies should obtain express affirmative consent before making material retroactive changes to privacy representations
- material change at a minimum includes sharing consumer information with 3Ps after committing at the time of collection not to share the data
Define:
privacy notice
- external statement that provides transparency concerning the org’s privacy practices
- how it collects, uses, shares, retains and discloses PI based on org’s privacy policy
organization can communicate privacy notice to consumer by:
- making notice accessible online
- making notice accessible in places of business
layered privacy notice approach
- short notice: top layer that summarizes notice’s scope and basic points about the org’s practice for personal information, collection, choice, use and disclosure
- full notice: comprehensive information on disclosure that articulates organization’s privacy notice in its entirety
Define:
just-in-time notice
notice at or before point of info collection or before a consumer accepts a service or product
Define:
privacy dashboard
offers a summary of privacy-related info in a format that is intended to be easy to access and navigate
Define:
double or confirmed opt-in
consumer first indicates interest in a communication list and then confirms that interest in response to the follow-up email
no option to opt
- when an organization uses or collects the consumer’s data because that org has been given implied authority to share PI
- e.g., a consumer who orders her product online expects her PI to be shared with the shipping company, credit card processor, etc.
good rule of thumb: channel for marketing should be…
chanel for exercising a user preference
privacy risk management
- process that identifies and assesses the risk to an org’s information assets and then implements appropriate mitigation strategies to reduce or eliminate those risks
- often includes conducting PIAs, vendor/third-party risk aseessments, data breach readiness assessments
Define:
organizational code of ethics
- helps in assessing benefits and risks of processing personal data
- focuses on topics such as how to respect individuals whose PI held by org; downstream uses of personal data; consequences of utilizing analytical tools; whether to collect data that the org does not need; how should the org design practices to ensure transparency, accountability and auditability
Define:
privacy risk
likelihood that individuals will experience problems resulting from data processing, and the impact of these problems should they occur
Define:
privacy impact assessment
- provides analysis of how personal information is handled to ensure handling conforms to applicable legal, regulatory and policy requirements regarding privacy
- determine risks and effects of collecting, maintaining and disseminating personal info in identifiable form
- examine and evaluate protections and alternative processes for handling information to mitigate potential privacy risks
Define:
privacy risk assessment
- core of PIA
- focuses on determining level of privacy risk by looking at the privacy impact and likelihood given the controls
precautions to consider in written contract with third-party vendor
- confidentiality provision
- no further use of shared information
- subcontractors should follow privacy and security protection terms in vendor’s K
- requirement to notify and to disclose breach
- information security provisions
- end of relationship → return of data or deletion of data at conclusion of relationship
standards for vendor selection
- reputation
- financial condition and insurance
- information security controls to ensure data isn’t lost or stolen (e.g., SOC 2)
- secure transfer mechanisms for data
- appropriate disposal of information → appropriate destruction of data in any format or media
- employee training and user awareness
- vendor incident response
- org should be able to audit vendor’s activities to ensure compliance with contractual obligations
Define:
information security
protection of information for the purpose of preventing loss, unauthorized access, or misuse
What are the three key attributes of information security?
- confidentiality
- integrity
- availability
Define:
confidentiality
access to data is limited to authorized parties
Define:
integrity
assurance that the data is authentic and complete
Define:
availability
knowledge that the data is accessible, as needed, by those who are authorized to use it
Define:
security controls
mechanisms put in place to prevent, detect or correct a security incident
What are the three types of security controls?
- physical controls such as locks, security cameras and fences
- administrative controls such as incident response procedures and training
- technical controls such as firewalls, antivirus software, and access logs