Certified Information Privacy Manager 2025 Practice Test

IAPP-CIPM test Format | Course Contents | Course Outline | test Syllabus | test Objectives

EXAM NUMBER : IAPP-CIPM
EXAM NAME : Certified Information Privacy Manager
TOTAL QUESTIONS : 90
SCORED QUESTIONS : 70
TIME : 2 hours 30 minutes
PASSING SCORES : 300
PASSING PERCENTAGE : 60%

Make data privacy regulations work for your organization by understanding how to implement them in day-to-day operations. Learn to create a company vision, structure a data protection team, develop and implement system frameworks, communicate to stakeholders, measure performance and more.

- How to create a company vision
- How to structure the privacy team
- How to develop and implement a privacy program framework
- How to communicate to stakeholders
- How to measure performance
- The privacy program operational life cycle

The International Association of Privacy Professionals (IAPP) is the largest and most
comprehensive global information privacy community and resource. IAPP helps practitioners
develop and advance their careers, and organizations manage and protect their data.
The IAPP is a not-for-profit association founded in 2000 with a mission to define, support and
improve the privacy profession globally. We are committed to providing a forum for privacy
professionals to share best practices, track trends, advance privacy management issues, standardize
the designations for privacy professionals and provide education and guidance on opportunities in
the field of information privacy.
The IAPP is responsible for developing and launching the gold standard in privacy and data
protection certifications: the Certified Information Privacy Professional (CIPP), the Certified
Information Privacy Manager (CIPM) and the Certified Information Privacy Technologist
(CIPT). The CIPP, CIPM and CIPT are the leading privacy certifications for tens of thousands of
professionals around the world who serve the privacy, data protection, information auditing,
information security, data ethics, legal compliance and risk management needs of their
organizations.
In addition, the IAPP offers a full suite of educational and professional development services and
holds annual conferences that are recognized internationally as the leading forums for the
discussion and debate of issues related to privacy policy and practice.

Contents covered in these IAPP CIPM Questions
---------------------------------------------

- Define program scope and develop a privacy strategy.
- Identify the source, types and uses of personal information (PI) within the organization.
- Understand the organization’s business model and risk appetite.
- Choose applicable governance model.
- Define the structure of the privacy team.
- Identify stakeholders and internal partners.
- Communicate organizational vision and mission statement.
- Create awareness of the organization’s privacy program internally and externally.
- Ensure employees have access to policies and procedures and updates relative to their role(s).
- Adopt privacy program vocabulary (e.g., incident vs breach).

- Indicate in-scope laws, regulations and standards applicable to the program.
- Understand territorial, sectoral and industry regulations, laws, codes of practice and/or self-certification mechanisms.
- Understand penalties for non-compliance.
- Understand scope and authority of oversight agencies.
- Understand privacy implications and territorial scope when doing business or basing operations in other countries with differing privacy laws.
- Understand the privacy risks posed by the use of AI in the business environment.

- Create policies and processes to be followed across all stages of the privacy program life cycle.
- Establish the organizational model, responsibilities, and reporting structure appropriate to size of organization.
- Define policies appropriate for the data processed by the organization, taking into account legal and ethical requirements.
- Identify collection points considering transparency requirements and data quality issues around collection of data.
- Create a plan for breach management.
- Create a plan for complaint handling procedures.
- Create data retention and disposal policies and procedures.

- Clarify roles and responsibilities.
- Define roles and responsibilities of the privacy team and stakeholders.
- Define the roles and responsibilities for managing the sharing and disclosure of data for internal and external use.
- Define roles and responsibilities for breach response by function, including stakeholders and their accountability to various internal and external partners
- detection teams
- IT
- HR
- vendors
- regulators
- oversight teams

- Define privacy metrics for oversight and governance.
- Create metrics per audience and/or identify intended audience for metrics with clear processes describing purpose, value and reporting of metrics.
- Understand purposes, types and life cycles of audits in evaluating effectiveness of controls throughout organization’s operations, systems and processes.
- Establish monitoring and enforcement systems to track multiple jurisdictions for changes in privacy law to ensure continuous alignment.

- Establish training and awareness activities.
- Develop targeted employee, management and contractor trainings at all stages of the privacy life cycle.
- Create continuous privacy program activities
- education and awareness
- monitoring internal compliance
- program assurance
- including audits
- complaint handling procedures

Domain III: Privacy Program Operational Life Cycle: Assessing Data
- Document data governance systems.
- Map data inventories, map data flows, map data life cycle and system integrations.
- Measure policy compliance against internal and external requirements.
- Determine desired state and perform gap analysis against an accepted standard or law.
- Evaluate processors and third-party vendors.
- Identify and assess risks of outsourcing the processing of personal data
- contractual requirements
- rules of international data transfers
- Carry out assessments at the most appropriate functional level within the organization
- procurement
- internal audit
- information security
- physical security
- data protection authority

- Evaluate physical and environmental controls.
- Identify operational risks of physical locations (e.g., data centers and offices) and physical controls
- document retention and destruction
- media sanitization and disposal
- device forensics and device security
- Evaluate technical controls.
- Identify operational risks of digital processing
- servers
- storage
- infrastructure and cloud

- Review and set limits on use of personal data (e.g., role-based access).
- Review and set limits on records retention.
- Determine the location of data, including cross-border data flows.
- Collaborate with relevant stakeholders to identify and evaluate technical controls.
- Evaluate risks associated with shared data in mergers, acquisitions, and divestitures.
- Complete due diligence procedures.
- Evaluate contractual and data sharing obligations, including laws, regulations and standards.
- Conduct risk and control alignment.

Domain IV: Privacy Program Operational Life Cycle: Protecting Personal Data
- Apply information security practices and policies.
- Classify data to the applicable classification scheme
- public
- confidential
- restricted
- Understand purposes and limitations of different controls.
- Identify risks and implement applicable access controls.
- Use appropriate technical, administrative and organizational measures to mitigate any residual risk.

- Integrate the main principles of Privacy by Design (PbD).
- Integrate privacy throughout the System Development Life Cycle (SDLC).
- Integrate privacy throughout business process.
- Apply organizational guidelines for data use and ensure technical controls are enforced.
- Verify that guidelines for secondary uses of data are followed.
- Verify that the safeguards such as vendor and HR policies, procedures and contracts are applied.
- Ensure applicable employee access controls and data classifications are in use.
- Collaborate with privacy technologists to enable technical controls for obfuscation, data minimization, security and other privacy enhancing technologies.

Domain V: Privacy Program Operational Life Cycle: Sustaining Program Performance
- Use metrics to measure the performance of the privacy program.
- Determine appropriate metrics for different objectives and analyze data collected through metrics
- trending
- ROI
- business resiliency
- Collect metrics to link training and awareness activities to reductions in privacy events and continuously Improve the privacy program based on the metrics collected.

- Audit the privacy program.
- Understand the types, purposes, and life cycles of audits in evaluating effectiveness of controls throughout organization’s operations, systems and processes.
- Select applicable forms of monitoring based upon program goals
- audits
- controls
- subcontractors
- Complete compliance monitoring through auditing of privacy policies, controls and standards, including against industry standards, regulatory and/or legislative changes.

- Manage continuous assessment of the privacy program.
- Conduct risk assessments on systems, applications, processes, and activities.
- Understand the purpose and life cycle for each assessment type
- PIA
- DPIA
- TIA
- LIA
- PTA
- Implement risk mitigation and communications with internal and external stakeholders after mergers, acquisitions, and divestitures.

Domain VI: Privacy Program Operational Life Cycle: Responding to Requests and Incidents
- Respond to data subject access requests and privacy rights.
- Ensure privacy notices and policies are transparent and clearly articulate data subject rights.
- Comply with organization’s privacy policies around consent
- withdrawals of consent
- rectification requests
- objections to processing
- access to data and complaints

- Understand and comply with established international, federal, and state legislations around data subject’s rights of control over their personal information
- GDPR
- HIPAA
- CAN-SPAM
- FOIA
- CCPA/CPRA

- Follow organizational incident handling and response procedures.
- Conduct an incident impact assessment.
- Perform containment activities.
- Identify and implement remediation measures.
- Communicate to stakeholders in compliance with jurisdictional, global and business requirements.
- Engage privacy team to review facts, determine actions and execute plans.
- Maintain an incident register and associated records of the incident.
- Evaluate and modify current incident response plan.
- Carry out post-incident reviews to Improve the effectiveness of the plan.
- Implement changes to reduce the likelihood and/or impact of future breaches.

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Certified Information Privacy Manager
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Question: 112
Which is NOT an influence on the privacy environment external to an organization?
A. Management team priorities
B. Regulations
C. Consumer demand
D. Technological advances
Answer: C
Question: 113
What is the key factor that lays the foundation for all other elements of a privacy program?
A. The applicable privacy regulations
B. The structure of a privacy team
C. A privacy mission statement
D. A responsible internal stakeholder
Answer: A
Question: 114
Which statement is FALSE regarding the use of technical security controls?
A. Most privacy legislation enumerates the types of technical security controls that must be implemented
B. Technical security controls are part of a data governance strategy
C. Technical security controls deployed for one jurisdiction often satisfy another jurisdiction
D. A security engineer should be involved with the deployment of technical security controls
Answer: C
Question: 115
SCENARIO
Please use the following to answer the next question:
Paul Daniels, with years of experience as a CEO, is thinking about his son Carlton�s successful venture, Gadgo. A
technological innovator in the communication industry that quickly became profitable, Gadgo has moved beyond its
startup phase. While it has retained its vibrant energy, Paul fears that under Carlton�s direction, the company may not
be taking its risks or obligations as seriously as it needs to. Paul has hired you, a privacy Consultant, to assess the
company and report to both father and son. �Carlton won�t listen to me,� Paul says, �but he may pay attention to an
expert.�
Gadgo�s workplace is a clubhouse for innovation, with games, toys, snacks, espresso machines, giant fish tanks and
even an iguana who regards you with little interest. Carlton, too, seems bored as he describes to you the company�s
procedures and technologies for data protection. It�s a loose assemblage of controls, lacking consistency and with
plenty of weaknesses. �This is a technology company,� Carlton says. �We create. We innovate. I don�t want
unnecessary measures that will only slow people down and clutter their thoughts.�
The meeting lasts until early evening. Upon leaving, you walk through the office. It looks as if a strong windstorm has
recently blown through, with papers scattered across desks and tables and even the floor. A �cleaning crew� of one
teenager is emptying the trash bins. A few computers have been left on for the night; others are missing. Carlton takes
note of your attention to this: �Most of my people take their laptops home with them, or use their own tablets or
phones. I want them to use whatever helps them to think and be ready day or night for that great insight. It may only
come once!�
What phase in the Privacy Maturity Model (PMM) does Gadgo�s privacy program best exhibit?
A. Ad hoc
B. Defined
C. Repeatable
D. Managed
Answer: A
Explanation:
Reference: https://vvena.nl/wp-content/uploads/2018/04/aicpa_cica_privacy_maturity_model.pdf (page 2)
Question: 116
SCENARIO
Please use the following to answer the next question:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has
found some degree of disorganization after touring the company headquarters. His uncle Henry has always focused on
production C not data processing C and Anton is concerned. In several storage rooms, he has found paper files, disks,
and old computers that appear to contain the personal data of current and former employees and customers. Anton
knows that a single break-in could irrevocably damage the company�s relationship with its loyal customers. He intends
to set a goal of guaranteed zero loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the
company. However, Kenneth C his uncle�s vice president and longtime confidante C wants to hold off on Anton�s idea
in favor of converting any paper records held at the company to electronic storage. Kenneth believes this process
would only take one or two years. Anton likes this idea; he envisions a password-protected system that only he and
Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will
simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware store down
the street will be responsible for their own information management. Then, any unneeded subsidiary data still in
Anton�s possession can be destroyed within the next few years.
After learning of a accurate security incident, Anton realizes that another crucial step will be notifying customers.
Kenneth insists that two lost hard drives in question are not cause for concern; all of the data was encrypted and not
sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all
employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy
protection. Kenneth oversaw the development of the company�s online presence about ten years ago, but Anton is not
confident about his understanding of accurate online marketing laws. Anton is assigning another trusted employee with a
law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should
be safe for another five years, at which time he can order another check. Documentation of this analysis will show
auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the effort is worth it.
Anton wants his uncle�s legacy to continue for many years to come.
Which of Anton�s plans for improving the data management of the company is most unachievable?
A. His initiative to achieve regulatory compliance
B. His intention to transition to electronic storage
C. His objective for zero loss of personal information
D. His intention to send notice letters to customers and employees
Answer: A
Question: 117
What is the best way to understand the location, use and importance of personal data within an organization?
A. By analyzing the data inventory
B. By testing the security of data systems
C. By evaluating methods for collecting data
D. By interviewing employees tasked with data entry
Answer: C
Question: 118
SCENARIO
Please use the following to answer the next question:
For 15 years, Albert has worked at Treasure Box C a mail order company in the United States (U.S.) that used to sell
decorative candles around the world, but has recently decided to limit its shipments to customers in the 48 contiguous
states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not
being promoted, coupled with his accurate interest in issues of privacy protection, have motivated Albert to be an agent
of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives
aware of lapses in the company�s privacy program. He feels certain he will be rewarded with a promotion for
preventing negative consequences resulting from the company�s outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA
(Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful
way to measure Treasure Box�s ability to protect personal data. Albert has noticed that Treasure Box fails to meet the
requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company
with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company�s commitment to
the security of customer and employee personal data against external threats. However, Albert worries about the high
turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces
every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours
and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two accurate security incidents. The company has responded to the incidents with
internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence
indicates that many people still harbor mistrust. Albert wants to help the company recover. He knows there is at least
one incident the public in unaware of, although Albert does not know the details. He believes the company�s insistence
on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to
help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient
procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company�s accurate business
maneuvers will also impress the interviewers. For example, Albert is aware of the company�s intention to acquire a
medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the
job.
Based on Albert�s observations regarding accurate security incidents, which of the following should he suggest as a
priority for Treasure Box?
A. Appointing an internal ombudsman to address employee complaints regarding hours and pay.
B. Using a third-party auditor to address privacy protection issues not recognized by the prior internal audits.
C. Working with the Human Resources department to make screening procedures for potential employees more
rigorous.
D. Evaluating the company�s ability to handle personal health information if the plan to acquire the medical supply
company goes forward
Answer: D
Question: 119
SCENARIO
Please use the following to answer the next question:
For 15 years, Albert has worked at Treasure Box C a mail order company in the United States (U.S.) that used to sell
decorative candles around the world, but has recently decided to limit its shipments to customers in the 48 contiguous
states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not
being promoted, coupled with his accurate interest in issues of privacy protection, have motivated Albert to be an agent
of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives
aware of lapses in the company�s privacy program. He feels certain he will be rewarded with a promotion for
preventing negative consequences resulting from the company�s outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA
(Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful
way to measure Treasure Box�s ability to protect personal data. Albert has noticed that Treasure Box fails to meet the
requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company
with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company�s commitment to
the security of customer and employee personal data against external threats. However, Albert worries about the high
turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces
every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours
and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two accurate security incidents. The company has responded to the incidents with
internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence
indicates that many people still harbor mistrust. Albert wants to help the company recover. He knows there is at least
one incident the public in unaware of, although Albert does not know the details. He believes the company�s insistence
on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to
help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient
procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company�s accurate business
maneuvers will also impress the interviewers. For example, Albert is aware of the company�s intention to acquire a
medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the
job.
The company may start to earn back the trust of its customer base by following Albert�s suggestion regarding which
handling procedure?
A. Access
B. Correction
C. Escalation
D. Data Integrity
Answer: D
Question: 120
�Collection,� �access� and �destruction� are aspects of what privacy management process?
A. The data governance strategy
B. The breach response plan
C. The metric life cycle
D. The business case
Answer: A
Question: 121
SCENARIO
Please use the following to answer the next question:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has
found some degree of disorganization after touring the company headquarters. His uncle Henry has always focused on
production C not data processing C and Anton is concerned. In several storage rooms, he has found paper files, disks,
and old computers that appear to contain the personal data of current and former employees and customers. Anton
knows that a single break-in could irrevocably damage the company�s relationship with its loyal customers. He intends
to set a goal of guaranteed zero loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the
company. However, Kenneth C his uncle�s vice president and longtime confidante C wants to hold off on Anton�s idea
in favor of converting any paper records held at the company to electronic storage. Kenneth believes this process
would only take one or two years. Anton likes this idea; he envisions a password-protected system that only he and
Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will
simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware store down
the street will be responsible for their own information management. Then, any unneeded subsidiary data still in
Anton�s possession can be destroyed within the next few years.
After learning of a accurate security incident, Anton realizes that another crucial step will be notifying customers.
Kenneth insists that two lost hard drives in question are not cause for concern; all of the data was encrypted and not
sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all
employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy
protection. Kenneth oversaw the development of the company�s online presence about ten years ago, but Anton is not
confident about his understanding of accurate online marketing laws. Anton is assigning another trusted employee with a
law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should
be safe for another five years, at which time he can order another check. Documentation of this analysis will show
auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the effort is worth it.
Anton wants his uncle�s legacy to continue for many years to come.
What would the company�s legal team most likely recommend to Anton regarding his planned communication with
customers?
A. To send consistent communication
B. To shift to electronic communication
C. To delay communications until local authorities are informed
D. To consider under what circumstances communication is necessary
Answer: D
Question: 122
SCENARIO
Please use the following to answer the next question:
For 15 years, Albert has worked at Treasure Box C a mail order company in the United States (U.S.) that used to sell
decorative candles around the world, but has recently decided to limit its shipments to customers in the 48 contiguous
states. Despite his years of experience, Albert is often overlooked for managerial positions. His frustration about not
being promoted, coupled with his accurate interest in issues of privacy protection, have motivated Albert to be an agent
of positive change.
He will soon interview for a newly advertised position, and during the interview, Albert plans on making executives
aware of lapses in the company�s privacy program. He feels certain he will be rewarded with a promotion for
preventing negative consequences resulting from the company�s outdated policies and procedures.
For example, Albert has learned about the AICPA (American Institute of Certified Public Accountans)/CICA
(Canadian Institute of Chartered Accountants) Privacy Maturity Model (PMM). Albert thinks the model is a useful
way to measure Treasure Box�s ability to protect personal data. Albert has noticed that Treasure Box fails to meet the
requirements of the highest level of maturity of this model; at his interview, Albert will pledge to assist the company
with meeting this level in order to provide customers with the most rigorous security available.
Albert does want to show a positive outlook during his interview. He intends to praise the company�s commitment to
the security of customer and employee personal data against external threats. However, Albert worries about the high
turnover rate within the company, particularly in the area of direct phone marketing. He sees many unfamiliar faces
every day who are hired to do the marketing, and he often hears complaints in the lunch room regarding long hours
and low pay, as well as what seems to be flagrant disregard for company procedures.
In addition, Treasure Box has had two accurate security incidents. The company has responded to the incidents with
internal audits and updates to security safeguards. However, profits still seem to be affected and anecdotal evidence
indicates that many people still harbor mistrust. Albert wants to help the company recover. He knows there is at least
one incident the public in unaware of, although Albert does not know the details. He believes the company�s insistence
on keeping the incident a secret could be a further detriment to its reputation. One further way that Albert wants to
help Treasure Box regain its stature is by creating a toll-free number for customers, as well as a more efficient
procedure for responding to customer concerns by postal mail.
In addition to his suggestions for improvement, Albert believes that his knowledge of the company�s accurate business
maneuvers will also impress the interviewers. For example, Albert is aware of the company�s intention to acquire a
medical supply company in the coming weeks.
With his forward thinking, Albert hopes to convince the managers who will be interviewing him that he is right for the
job.
What is one important factor that Albert fails to consider regarding Treasure Box�s response to their accurate security
incident?
A. Who has access to the data
B. What the nature of the data is
C. How data at the company is collected
D. How long data at the company is kept
Answer: D
Question: 123
An organization�s business continuity plan or disaster recovery plan does NOT typically include what?
A. Recovery time objectives
B. Emergency Response Guidelines
C. Statement of organizational responsibilities
D. Retention schedule for storage and destruction of information
Answer: D
Question: 124
SCENARIO
Please use the following to answer the next question:
Henry Home Furnishings has built high-end furniture for nearly forty years. However, the new owner, Anton, has
found some degree of disorganization after touring the company headquarters. His uncle Henry has always focused on
production C not data processing C and Anton is concerned. In several storage rooms, he has found paper files, disks,
and old computers that appear to contain the personal data of current and former employees and customers. Anton
knows that a single break-in could irrevocably damage the company�s relationship with its loyal customers. He intends
to set a goal of guaranteed zero loss of personal information.
To this end, Anton originally planned to place restrictions on who was admitted to the physical premises of the
company. However, Kenneth C his uncle�s vice president and longtime confidante C wants to hold off on Anton�s idea
in favor of converting any paper records held at the company to electronic storage. Kenneth believes this process
would only take one or two years. Anton likes this idea; he envisions a password-protected system that only he and
Kenneth can access.
Anton also plans to divest the company of most of its subsidiaries. Not only will this make his job easier, but it will
simplify the management of the stored data. The heads of subsidiaries like the art gallery and kitchenware store down
the street will be responsible for their own information management. Then, any unneeded subsidiary data still in
Anton�s possession can be destroyed within the next few years.
After learning of a accurate security incident, Anton realizes that another crucial step will be notifying customers.
Kenneth insists that two lost hard drives in question are not cause for concern; all of the data was encrypted and not
sensitive in nature. Anton does not want to take any chances, however. He intends on sending notice letters to all
employees and customers to be safe.
Anton must also check for compliance with all legislative, regulatory, and market requirements related to privacy
protection. Kenneth oversaw the development of the company�s online presence about ten years ago, but Anton is not
confident about his understanding of accurate online marketing laws. Anton is assigning another trusted employee with a
law background the task of the compliance assessment. After a thorough analysis, Anton knows the company should
be safe for another five years, at which time he can order another check. Documentation of this analysis will show
auditors due diligence.
Anton has started down a long road toward improved management of the company, but he knows the effort is worth it.
Anton wants his uncle�s legacy to continue for many years to come.
Which important principle of Data Lifecycle Management (DLM) will most likely be compromised if Anton executes
his plan to limit data access to himself and Kenneth?
A. Practicing data minimalism
B. Ensuring data retrievability
C. Implementing clear policies
D. Ensuring adequacy of infrastructure
Answer: A

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