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Certified Information Privacy Professional/Canada (CIPP/C) Practice Test

IAPP-CIPP-C test Format | Course Contents | Course Outline | test Syllabus | test Objectives

Exam Code: IAPP CIPP/C
Exam Name: IAPP Certified Information Privacy Professional/Canada (CIPP/C)
Exam Format: Multiple choice questions (MCQs)
Number of Questions: 90 questions
Time Allotted: 2.5 hours (150 minutes)
Passing Score: The IAPP uses a scaled scoring system, but the raw passing mark is generally considered to be around 75% (i.e., approximately 68 correct answers out of 90). The passing score is 300 on a scale of 100-500.

I. Introduction to Canadian Privacy Environment 20%

- Structure of Canadian law (constitutional foundation, federalism, Charter of Rights and Freedoms, common law vs. civil law in Quebec)
- Canadian legal system and sources of privacy law
- Key privacy concepts (personal information, consent, accountability, openness, etc.)
- Evolution of privacy law in Canada
- Role of privacy commissioners (federal OPC and provincial commissioners)
- Enforcement models (ombudsman vs. order-making powers)

II. Federal Private-Sector Privacy Law: PIPEDA and Substantially Similar Provincial Laws 35–40%

- Application and Scope

- Public vs. private sector
- Commercial activities
- Employee personal information in federally regulated organizations
- Substantially similar provincial laws (BC PIPA, Alberta PIPA, Quebec Private Sector Act)
- Health information laws (when they override PIPEDA (BC, Alberta, Ontario, New Brunswick, Newfoundland & Labrador, etc.)

- The 10 Fair Information Principles (Schedule 1 of PIPEDA)

- Accountability
- Identifying purposes
- Consent (including implied/expressed, opt-in/opt-out, withdrawal)
- Limiting collection
- Limiting use, disclosure, and retention
- Accuracy
- Safeguards
- Openness
- Individual access
- Challenging compliance

- Key compliance obligations

- Privacy policies and notices
- Privacy management programs
- Appointment of a privacy officer
- Breach notification requirements (mandatory since Nov 2018)
- Cross-border data flows and transfers (Accountability principle, APEC CBPR, EU adequacy decisions, etc.)
- Children’s privacy and CASL interaction

- Oversight and enforcement

- OPC investigations and findings
- Commissioner-initiated complaints
- Federal Court hearings and remedies
- New powers under proposed Bill C-27 / CPPA (if enacted by test date)

III. Provincial Laws 25–30%

- Public Sector Privacy Laws

- Federal: Privacy Act
- Provincial: FIPPA/MFIPPA (Ontario), FOIP (Alberta), ATIPPA (Newfoundland), etc.
- Municipal: MFIPPA (Ontario)

- Provincial Private-Sector Privacy Laws

- Quebec Law 25 (formerly Law 25 – Act to modernize legislative provisions respecting the protection of personal information)
- British Columbia PIPA
- Alberta PIPA
- Differences from PIPEDA (consent, breach notification, private right of action in Quebec, etc.)

- Provincial Health Information Acts (very high yield)

- Ontario PHIPA (Personal Health Information Protection Act)
- British Columbia Personal Information Protection Act (health provisions)
- Alberta HIA
- New Brunswick PHIPAA
- Role of health information custodians, agents, circle of care, express consent requirements

IV. Emerging Developments and Specialized Topics 15–20%

- Anti-spam legislation (CASL) – interaction with privacy
- Artificial intelligence, automated decision-making (Directive A-1, Bill C-27/CPPA proposed rules)
- De-identification, anonymization, and pseudonymization standards
- Privacy by Design (PbD) and privacy impact assessments (PIAs/TIAs)
- Online behavioral advertising (OPC guidelines)
- Workplace privacy (video surveillance, biometric data, monitoring, drug testing)
- Transborder data flows and international transfers
- Children and minors’ privacy (Quebec, OPC guidelines)
- Political party and election privacy (provincial election laws)
- Proposed Consumer Privacy Protection Act (CPPA) / Bill C-27 / Digital Charter Implementation Act (if passed by test date – know the major proposed changes)

- High-Yield Topics (appear very frequently)

- Differences between PIPEDA and provincial health laws (especially Ontario PHIPA)
- Breach reporting requirements (federal vs. Alberta vs. Quebec)
- Consent exceptions (Schedule 1, clause 4.3)
- Substantially similar designation process
- Health Information Custodian vs. agent under PHIPA
- Quebec Law 25 requirements (DPO appointment, privacy impact assessments, default privacy settings)
- Cross-border transfers and accountability

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Question: 42
What is the most important action an organization can take to comply with the FTC position on retroactive changes to a privacy policy?
A. Describing the policy changes on its website.
B. Obtaining affirmative consent from its customers.
C. Publicizing the policy changes through social media.
D. Reassuring customers of the security of their information.
Answer: B
Explanation:
Reference: https://iapp.org/news/a/what-does-the-ccpas-purpose-limitation-mean-for-businesses/
Question: 43
What is the main purpose of the CAN-SPAM Act?
A. To diminish the use of electronic messages to send sexually explicit materials
B. To authorize the states to enforce federal privacy laws for electronic marketing
C. To empower the FTC to create rules for messages containing sexually explicit content
D. To ensure that organizations respect individual rights when using electronic advertising
Answer: D
Explanation:
Reference: https://www.ftc.gov/tips-advice/business-center/guidance/can-spam-act-compliance-guide- business
Question: 44
SCENARIO
Please use the following to answer the next QUESTION
Noah is trying to get a new job involving the management of money. He has a poor personal credit rating, but he has made better financial decisions in the past two years.
One potential employer, Arnie�s Emporium, recently called to tell Noah he did not get a position. As part of the application process, Noah signed a consent form allowing
the employer to request his credit report from a consumer reporting agency (CRA). Noah thinks that the report hurt his chances, but believes that he may not ever know
whether it was his credit that cost him the job. However, Noah is somewhat relieved that he was not offered this particular position. He noticed that the store where he
interviewed was extremely disorganized. He imagines that his credit report could still be sitting in the office, unsecured.
Two days ago, Noah got another interview for a position at Sam�s Market. The interviewer told Noah that his credit report would be a factor in the hiring decision. Noah
was surprised because he had not seen anything on paper about this when he applied.
Regardless, the effect of Noah�s credit on his employability troubles him, especially since he has tried so hard to Boost it. Noah made his worst financial decisions fifteen
years ago, and they led to bankruptcy. These were decisions he made as a young man, and most of his debt at the time consisted of student loans, credit card debt, and a few
unpaid bills C all of which Noah is still working to pay off. He often laments that decisions he made fifteen years ago are still affecting him today.
In addition, Noah feels that an experience investing with a large bank may have contributed to his financial troubles. In 2007, in an effort to earn money to help pay off his
debt, Noah talked to a customer service representative at a large investment company who urged him to purchase stocks. Without understanding the risks, Noah agreed.
Unfortunately, Noah lost a great deal of money.
After losing the money, Noah was a customer of another financial institution that suffered a large security breach. Noah was one of millions of customers whose personal
information was compromised. He wonders if he may have been a victim of identity theft and whether this may have negatively affected his credit.
Noah hopes that he will soon be able to put these challenges behind him, build excellent credit, and find the perfect job.
Consumers today are most likely protected from situations like the one Noah had buying stock because of which federal action or legislation?
A. The rules under the Fair Debt Collection Practices Act.
B. The creation of the Consumer Financial Protection Bureau.
C. Federal Trade Commission investigations into �unfair and deceptive� acts or practices.
D. Investigations of �abusive� acts and practices under the Dodd-Frank Wall Street Reform and Consumer Protection Act.
Answer: D
Question: 45
SCENARIO
Please use the following to answer the next QUESTION:
Cheryl is the sole owner of Fitness Coach, Inc., a medium-sized company that helps individuals realize their physical fitness goals through classes, individual instruction,
and access to an extensive indoor gym. She has owned the company for ten years and has always been concerned about protecting customer�s privacy while maintaining the
highest level of service. She is proud that she has built long-lasting customer relationships.
Although Cheryl and her staff have tried to make privacy protection a priority, the company has no formal privacy policy. So Cheryl hired Janice, a privacy professional, to
help her develop one.
After an initial assessment, Janice created a first of a new policy. Cheryl read through the draft and was concerned about the many changes the policy would bring
throughout the company. For example, the draft policy stipulates that a customer�s personal information can only be held for one year after paying for a service such as a
session with personal trainer. It also promises that customer information will not be shared with third parties without the written consent of the customer. The wording of
these rules worry Cheryl since stored personal information often helps her company to serve her customers, even if there are long pauses between their visits. In addition,
there are some third parties that provide crucial services, such as aerobics instructors who teach classes on a contract basis. Having access to customer files and
understanding the fitness levels of their students helps instructors to organize their classes.
Janice understood Cheryl�s concerns and was already formulating some ideas for revision. She tried to put Cheryl at ease by pointing out that customer data can still be kept,
but that it should be classified according to levels of sensitivity. However, Cheryl was skeptical. It seemed that classifying data and treating each type differently would
cause undue difficulties in the company�s day-to-day operations. Cheryl wants one simple data storage and access system that any employee can access if needed.
Even though the privacy policy was only a draft, she was beginning to see that changes within her company were going to be necessary. She told Janice that she would be
more comfortable with implementing the new policy gradually over a period of several months, one department at a time. She was also interested in a layered approach by
creating documents listing applicable parts of the new policy for each department.
What is the best reason for Cheryl to follow Janice�s suggestion about classifying customer data?
A. It will help employees stay better organized
B. It will help the company meet a federal mandate
C. It will increase the security of customers� personal information (PI)
D. It will prevent the company from collecting too much personal information (PI)
Answer: C
Explanation:
Reference: https://eits.uga.edu/access_and_security/infosec/pols_regs/policies/dcps/
Question: 46
SCENARIO
Please use the following to answer the next QUESTION:
You are the chief privacy officer at HealthCo, a major hospital in a large U.S. city in state A. HealthCo is a HIPAA-covered entity that provides healthcare services to more
than 100,000 patients. A third-party cloud computing service provider, CloudHealth, stores and manages the electronic protected health information (ePHI) of these
individuals on behalf of HealthCo. CloudHealth stores the data in state B. As part of HealthCo�s business associate agreement (BAA) with CloudHealth, HealthCo requires
CloudHealth to implement security measures, including industry standard encryption practices, to adequately protect the data. However, HealthCo did not perform due
diligence on CloudHealth before entering the contract, and has not conducted audits of CloudHealth�s security measures.
A CloudHealth employee has recently become the victim of a phishing attack. When the employee unintentionally clicked on a link from a suspicious email, the PHI of
more than 10,000 HealthCo patients was compromised. It has since been published online. The HealthCo cybersecurity team quickly identifies the perpetrator as a known
hacker who has launched similar attacks on other hospitals C ones that exposed the PHI of public figures including celebrities and politicians.
During the course of its investigation, HealthCo discovers that CloudHealth has not encrypted the PHI in accordance with the terms of its contract. In addition, CloudHealth
has not provided privacy or security training to its employees. Law enforcement has requested that HealthCo provide its investigative report of the breach and a copy of the
PHI of the individuals affected.
A patient affected by the breach then sues HealthCo, claiming that the company did not adequately protect the individual�s ePHI, and that he has suffered substantial harm as
a result of the exposed data. The patient�s attorney has submitted a discovery request for the ePHI exposed in the breach.
What is the most significant reason that the U.S. Department of Health and Human Services (HHS) might impose a penalty on HealthCo?
A. Because HealthCo did not require CloudHealth to implement appropriate physical and administrative measures to safeguard the ePHI
B. Because HealthCo did not conduct due diligence to verify or monitor CloudHealth�s security measures
C. Because HIPAA requires the imposition of a fine if a data breach of this magnitude has
occurred
D. Because CloudHealth violated its contract with HealthCo by not encrypting the ePHI
Answer: B
Question: 47
What privacy concept grants a consumer the right to view and correct errors on his or her credit report?
A. Access.
B. Notice.
C. Action.
D. Choice.
Answer: B
Question: 48
The Family Educational Rights and Privacy Act (FERPA) requires schools to do all of the following EXCEPT?
A. Verify the identity of students who make requests for access to their records.
B. Provide students with access to their records within a specified amount of time.
C. Respond to all reasonable student requests regarding explanation of their records.
D. Obtain student authorization before releasing directory information in their records.
Answer: B
Explanation:
Reference: https://www2.ed.gov/policy/gen/guid/fpco/pdf/ferpa-disaster-guidance.pdf
Question: 49
In March 2012, the FTC released a privacy report that outlined three core principles for companies handling consumer data .
Which was NOT one of these principles?
A. Simplifying consumer choice.
B. Enhancing security measures.
C. Practicing Privacy by Design.
D. Providing greater transparency.
Answer: B
Explanation:
Reference: https://www.ftc.gov/news-events/press-releases/2012/03/ftc-issues-final-commission-report- protecting-consumer-privacy
Question: 50
SCENARIO
Please use the following to answer the next QUESTION
Matt went into his son�s bedroom one evening and found him stretched out on his bed typing on his laptop. �Doing your homework?� Matt asked hopefully.
�No,� the boy said. �I�m filling out a survey.�
Matt looked over his son�s shoulder at his computer screen. �What kind of survey?� �It�s asking QUESTION NO:s about my opinions.�
�Let me see,� Matt said, and began reading the list of QUESTION NO:s that his son had already answered. �It�s asking your opinions about the government and citizenship.
That�s a little odd. You�re only ten.�
Matt wondered how the web link to the survey had ended up in his son�s email inbox. Thinking the message might have been sent to his son by mistake he opened it and
read it. It had come from an entity called the Leadership Project, and the content and the graphics indicated that it was intended for children. As Matt read further he learned
that kids who took the survey were automatically registered in a contest to win the first book in a series about famous leaders.
To Matt, this clearly seemed like a marketing ploy to solicit goods and services to children. He asked his son if he had been prompted to give information about himself in
order to take the survey. His son told him he had been asked to give his name, address, telephone number, and date of birth, and to answer QUESTION NO:s about his
favorite games and toys.
Matt was concerned. He doubted if it was legal for the marketer to collect information from his son in the way that it was. Then he noticed several other commercial emails
from marketers advertising products for children in his son�s inbox, and he decided it was time to report the incident to the proper authorities.
Depending on where Matt lives, the marketer could be prosecuted for violating which of the following?
A. Investigative Consumer Reporting Agencies Act.
B. Unfair and Deceptive Acts and Practices laws.
C. Consumer Bill of Rights.
D. Red Flag Rules.
Answer: B
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