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Certified Information Privacy Technologist (CIPT) Questions 121–125 (page: 26)

Updated On: 1-Sep-2026

What is typically NOT performed by sophisticated Access Management (AM) techniques?

  1. Restricting access to data based on location.
  2. Restricting access to data based on user role.
  3. Preventing certain types of devices from accessing data.
  4. Preventing data from being placed in unprotected storage.

Answer(s): D

Explanation:

Why option D is the correct choice
Access-Management scope – Sophisticated AM controls who (user, role), where (geolocation), and how (device type) can access data. These controls are implemented through authentication, authorization, policy enforcement, and device posture checks. Option A – Restricting access by location is a classic location-based policy (e.g., denying VPN access from unauthorized regions). Option B – Restricting access by user role is the fundamental basis of role-based access control (RBAC). Option C – Preventing certain device types from accessing data is achieved via device-level policies (e.g., “only managed laptops may open the file”). Option D – Preventing data from being placed in unprotected storage is a data-at-rest protection concern (encryption, DLP, storage-level policies). It is not a function of access-management per se; it belongs to data-loss-prevention or encryption mechanisms rather than the access-control layer.
Therefore, D describes a capability that goes beyond the typical responsibilities of sophisticated AM techniques.
Why the other options are suitable for AM
Geographic restriction is enforced through network-level policies integrated with authentication/authorization flows. Role-based restriction is the core of access-control matrices and policy engines. Device-type restriction is realized via device posture assessments (e.g., MDM, Zero Trust networks) that feed into access decisions.


Reference:

National Institute of Standards and Technology (NIST) – Zero Trust Architecture : https://csrc.nist.gov/publications/detail/sp/800-207/final ISO/IEC 27001 – Access Control : https://www.iso.org/standard/54534.html (section A.9 on access control)



Properly configured databases and well-written website codes are the best protection against what online threat?

  1. Pharming.
  2. SQL injection.
  3. Malware execution.
  4. System modification.

Answer(s): B

Explanation:

Answer(s): B – SQL injection
Why B is correct
Databases store and process user-supplied data; if input is not validated or parameterized, an attacker can inject malicious SQL statements that alter queries, retrieve, modify, or delete data.
A well-written application (e.g., using prepared statements, input sanitization, and principle of least privilege) mitigates this risk by ensuring that only intended commands are executed. Therefore, the primary online threat that proper database configuration and clean code defend against is SQL injection .
Why the other options are less suitable

A: Pharming – Involves DNS spoofing or malicious redirects to fraudulent sites; it is mitigated by network-level controls (DNSSEC, TLS) rather than database or application code. C. Malware execution – Typically delivered via executable files, scripts, or compromised peripherals; protection relies on endpoint security, patch management, and user awareness, not directly on database configuration. D. System modification – Refers to unauthorized changes to OS or system files; defenses include hardening, integrity checking, and access controls, again outside the scope of database-code security.


Reference:

OWASP Top 10 – A03:2021 – Injection (SQL injection) – https://owasp.org/www-project-top-ten/2021/ NIST SP 800-53 Rev. 5 – Database Security Controls – https://csrc.nist.gov/publications/detail/sp/800-53/rev-5/final



A privacy engineer reviews a newly developed on-line registration page on a company's website. The purpose of the page is to enable corporate customers to submit a returns / refund request for physical goods. The page displays the following data capture fields: company name, account reference, company address, contact name, email address, contact phone number, product name, quantity, issue description and company bank account details. After her review, the privacy engineer recommends setting certain capture fields as `non-mandatory`. Setting which of the following fields as `non-mandatory` would be the best example of the principle of data minimization?

  1. The contact phone number field.
  2. The company address and name.
  3. The contact name and email address.
  4. The company bank account detail field.

Answer(s): D

Explanation:

Why D (company bank account details) is the best choice
The collection of bank-account information is only justified if it is strictly needed to process a payment; otherwise it adds no value to the refund request and creates a high-risk data element (financial data) that is unnecessary for the purpose. By marking this field non-mandatory , the engineer reduces the dataset to only what is essential – e.g., product details, quantity, and issue description – directly reflecting the GDPR principle of data minimisation (Article 5(1)(c)): collect only personal data that is adequate, relevant and limited to what is necessary for the purpose.
Why the other options are less suitable
A – Contact phone number – Telephone contact may be needed to clarify return issues or confirm the request; removing it could hinder legitimate communication and is not clearly excessive. B – Company address and name – Identification of the corporate customer is fundamental to routing the request and complying with any contractual or tax obligations; it cannot be deemed non-essential. C – Contact name and email address – These are typically required to personalise the request, send confirmations, or follow-up on the refund; they are more directly linked to the core purpose than bank-account data.


Reference:

International Association of Privacy Professionals (IAPP) – Data Minimisation and Purpose Limitation guideline: https://iapp.org/resources/article/data-minimisation/ UK Information Commissioner’s Office (ICO) – Guide to the General Data Protection Regulation (Chapter 3: Data minimisation): https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-gdpr/



What Privacy by Design (PbD) element should include a de-identification or deletion plan?

  1. Categorization.
  2. Remediation.
  3. Retention.
  4. Security

Answer(s): C

Explanation:

Answer(s): C – Retention
Retention policies define how long personal data is kept, when it is archived, and when it must be de-identified or securely deleted to meet legal, contractual, or purpose-limitation requirements. The PbD principle of “minimization and limitation of data processing” requires that data not be kept longer than necessary; consequently, a retention plan must prescribe mechanisms for timely de-identification or irreversible deletion once the retention period ends. Categorization merely sorts data into classes; it does not address the lifecycle actions needed for disposal. Remediation focuses on correcting inaccurate or non-compliant data after it has been identified, not on the scheduled removal of data that has met its retention limit. Security ensures data is protected while stored, but it does not specifically mandate the timing or method of data destruction that a retention schedule dictates.
Therefore, the retention element of Privacy-by-Design must incorporate a de-identification or deletion plan to enforce lawful data-lifecycle management.


Reference:

IAPP – Privacy By Design (PbD) Overview : https://iapp.org/resources/article/privacy-by-design-an-introductory-overview/ NIST Special Publication 800-53 Revision 5 – Data Retention and Disposal Controls : https://csrc.nist.gov/publications/detail/sp/800-53/rev-5/final
These sources outline how retention policies integrate de-identification and deletion obligations within a PbD framework.



Which of the following would be the best method of ensuring that Information Technology projects follow Privacy by Design (PbD) principles?

  1. Develop a technical privacy framework that integrates with the development lifecycle.
  2. Utilize Privacy Enhancing Technologies (PETs) as a part of product risk assessment and management.
  3. Identify the privacy requirements as a part of the Privacy Impact Assessment (PIA) process during development and evaluation stages.
  4. Develop training programs that aid the developers in understanding how to turn privacy requirements into actionable code and design level specifications.

Answer(s): A

Explanation:

Correct option: A – Develop a technical privacy framework that integrates with the development lifecycle.
Embedding a dedicated privacy framework into every phase of the software development lifecycle guarantees that privacy considerations are not an after-thought but a continuous design criterion, directly fulfilling the core tenet of Privacy by Design (PbD). This approach aligns with the IAPP’s PbD framework, which recommends a “privacy-by-design lifecycle” that maps privacy requirements to architecture, coding standards, testing, and deployment, thereby ensuring systematic compliance rather than isolated checks.
While options B, C, and D each address valuable privacy activities, they are subsets of a comprehensive lifecycle integration:
B (PETs in risk assessment) provides tools but does not institutionalize privacy controls across all stages. C (PIA during development) is essential for evaluation but treats privacy as a periodic assessment rather than an ongoing design driver. D (training developers) is necessary for capability building but alone cannot enforce consistent privacy practices without an overarching structural mechanism. Consequently, a dedicated technical privacy framework that is woven into requirements, design, implementation, and verification delivers the most robust, scalable, and auditable method for ensuring PbD adherence across IT projects.


Reference:

International Association of Privacy Professionals (IAPP), Privacy by Design: A Practical Guide – https://iapp.org/resources/detail/privacy-by-design-a-practical-guide National Institute of Standards and Technology (NIST), Privacy Framework – https://www.nist.gov/publications/privacy-framework-0



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