Classify the following scenario as major or minor non-conformity.
"The organization defined information access and usage policy and rolled it out across the organization No formal exercise, however, was conducted to prepare the policy During implementation, certain discrepancies came out and these were addressed through appropriate policy revisions though this created a lot of hue and cry in the organization and the policy was criticized for adversely affecting productivity But with appropriate revisions and passage of time, the policy has been accepted In a recently conducted external audit one incident has come to light wherein the usage and access policy has been violated by an employee twice As per the auditor this incident should have been identified by the organization In its explanation to the auditor the management informed that appropriate access and usage monitoring mechanisms have been put in place but admitted that there may have been some lapses".

• A. Minor
• B. Major
• C. Both Major & Minor
• D. None of the above

Which of the following best describes 'Processing'?

• A. Processing is storage and structuring personal data
• B. Processing is collection and use of personal data
• C. Processing is recording and destruction of personal data
• D. Processing is a blanket term used for the wide range of operations performed on personal data

FILL BLANK
PPP
Based on the visibility exercise, the consultants created a single privacy policy applicable to all the client relationships and business functions. The policy detailed out what PI company deals with, how it is used, what security measures are deployed for protection, to whom it is shared, etc. Given the need to address all the client relationships and business functions, through a single policy, the privacy policy became very lengthy and complex. The privacy policy was published on company's intranet and also circulated to heads of all the relationships and functions. W.r.t. some client relationships, there was also confusion whether the privacy policy should be notified to the end customers of the clients as the company was directly collecting PI as part of the delivery of BPM services. The heads found it difficult to understand the policy (as they could not directly relate to it) and what actions they need to perform. To assuage their concerns, a training workshop was conducted for 1 day. All the relationship and function heads attended the training. However, the training could not be completed in the given time, as there were numerous questions from the audiences and it took lot of time to clarify.
(Note: Candidates are requested to make and state assumptions wherever appropriate to reach a definitive conclusion) Introduction and Background XYZ is a major India based IT and Business Process Management (BPM) service provider listed at BSE and NSE. It has more than 1.5 lakh employees operating in 100 offices across 30 countries. It serves more than
500 clients across industry verticals - BFSI, Retail, Government, Healthcare, Telecom among others in Americas, Europe, Asia-Pacific, Middle East and Africa. The company provides IT services including application development and maintenance, IT Infrastructure management, consulting, among others. It also offers IT products mainly for its BFSI customers.
The company is witnessing phenomenal growth in the BPM services over last few years including Finance and Accounting including credit card processing, Payroll processing, Customer support, Legal Process Outsourcing, among others and has rolled out platform based services. Most of the company's revenue comes from the US from the BFSI sector. In order to diversify its portfolio, the company is looking to expand its operations in Europe. India, too has attracted company's attention given the phenomenal increase in domestic IT spend esp. by the government through various large scale IT projects. The company is also very aggressive in the cloud and mobility space, with a strong focus on delivery of cloud services. When it comes to expanding operations in Europe, company is facing difficulties in realizing the full potential of the market because of privacy related concerns of the clients arising from the stringent regulatory requirements based on EU General Data Protection Regulation (EU GDPR).
To get better access to this market, the company decided to invest in privacy, so that it is able to provide increased assurance to potential clients in the EU and this will also benefit its US operations because privacy concerns are also on rise in the US. It will also help company leverage outsourcing opportunities in the Healthcare sector in the US which would involve protection of sensitive medical records of the US citizens.
The company believes that privacy will also be a key differentiator in the cloud business going forward. In short, privacy was taken up as a strategic initiative in the company in early 2011.
Since XYZ had an internal consulting arm, it assigned the responsibility of designing and implementing an enterprise wide privacy program to the consulting arm. The consulting arm had very good expertise in information security consulting but had limited expertise in the privacy domain. The project was to be driven by CIO's office, in close consultation with the Corporate Information Security and Legal functions.
Given the confusion among relationship and function heads, how would you proceed to address the problem and ensure that policy is well understood and deployed? (250 to 500 words)

Which of the following is not an objective of VPI?

• A. To enable identification of processes, functions and relationships handling personal information
• B. Enable an organization to map its data operations and categorization of PI
• C. Assess the current state of data spread and transactions of the organization to map this against its privacy objectives
• D. None of the above

In which of the following cases would an organization be more prone to risk acceptance vs. risk mitigation?

• A. The organization uses exclusively a qualitative process lo measure risk
• B. The organization's risk tolerance is low
• C. The organization uses exclusively a quantitative process to measure risk
• D. The organization's risk tolerance is high