Podcast
Questions and Answers
Which parameter measures the risk of unauthorized disclosure harming stakeholders' interests?
Which parameter measures the risk of unauthorized disclosure harming stakeholders' interests?
What is the primary goal of risk management within an organization?
What is the primary goal of risk management within an organization?
What type of risk is associated with the quality or corruption of information?
What type of risk is associated with the quality or corruption of information?
Which of the following actions is NOT part of the risk management process?
Which of the following actions is NOT part of the risk management process?
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In the context of risk management, what constitutes a risk?
In the context of risk management, what constitutes a risk?
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Which parameter assesses the risk that information may not be accessible to intended users when needed?
Which parameter assesses the risk that information may not be accessible to intended users when needed?
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What can happen to an organization that fails to manage its risks effectively?
What can happen to an organization that fails to manage its risks effectively?
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What can be a consequence of viewing PDPA compliance merely as a legal exercise?
What can be a consequence of viewing PDPA compliance merely as a legal exercise?
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What characterizes leadership complacency regarding PDPA compliance?
What characterizes leadership complacency regarding PDPA compliance?
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Which of the following issues can result from improper training in an organization?
Which of the following issues can result from improper training in an organization?
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What impact does lack of oversight of third parties have on PDPA compliance?
What impact does lack of oversight of third parties have on PDPA compliance?
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Disjointed practices within an organization can lead to which of the following outcomes?
Disjointed practices within an organization can lead to which of the following outcomes?
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What is the primary purpose of a data classification policy?
What is the primary purpose of a data classification policy?
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Which element is NOT typically associated with a data classification policy?
Which element is NOT typically associated with a data classification policy?
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When developing a data classification policy, who should be responsible for classifying data?
When developing a data classification policy, who should be responsible for classifying data?
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What is a key factor to consider for each data classification level?
What is a key factor to consider for each data classification level?
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How should protection measures correspond with data classification levels?
How should protection measures correspond with data classification levels?
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Which of the following is NOT a proposed level of data classification?
Which of the following is NOT a proposed level of data classification?
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What role does data classification play in incident and security management procedures?
What role does data classification play in incident and security management procedures?
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Which type of solutions should the information security requirements include?
Which type of solutions should the information security requirements include?
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What is one of the main benefits of a well-planned data classification policy?
What is one of the main benefits of a well-planned data classification policy?
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What is an organization required to ensure when outsourcing data processing to a data intermediary?
What is an organization required to ensure when outsourcing data processing to a data intermediary?
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What should an organization consider if a potential data intermediary is based outside of Singapore?
What should an organization consider if a potential data intermediary is based outside of Singapore?
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How should access to personal data be controlled within an organization?
How should access to personal data be controlled within an organization?
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What can lead to a failure to comply with the Protection Obligation?
What can lead to a failure to comply with the Protection Obligation?
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What must organizations verify regarding personal data disclosures?
What must organizations verify regarding personal data disclosures?
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What should an organization's policy concerning personal data retention align with?
What should an organization's policy concerning personal data retention align with?
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What type of risks are associated with involvement from third-party service vendors?
What type of risks are associated with involvement from third-party service vendors?
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Which of the following is a common violation seen in enforcement decisions regarding the Protection Obligation?
Which of the following is a common violation seen in enforcement decisions regarding the Protection Obligation?
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What is critical for organizations to ensure when disposing of personal data?
What is critical for organizations to ensure when disposing of personal data?
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Which of the following best describes the consequences of a lack of defined data classification policies?
Which of the following best describes the consequences of a lack of defined data classification policies?
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What is a primary reason for the failures when engaging data intermediaries?
What is a primary reason for the failures when engaging data intermediaries?
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Which scenario exemplifies a failure due to insufficient data security measures by a data intermediary?
Which scenario exemplifies a failure due to insufficient data security measures by a data intermediary?
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What continuous obligation does an organisation have when outsourcing data processing to a data intermediary?
What continuous obligation does an organisation have when outsourcing data processing to a data intermediary?
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Which of the following is NOT a factor to watch out for when engaging data intermediaries?
Which of the following is NOT a factor to watch out for when engaging data intermediaries?
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What is a potential risk involved in the electronic processing of personal data?
What is a potential risk involved in the electronic processing of personal data?
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Which of the following indicates inadequate oversight by an organisation over a data intermediary?
Which of the following indicates inadequate oversight by an organisation over a data intermediary?
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What consequence may arise from a poor contract with a data intermediary?
What consequence may arise from a poor contract with a data intermediary?
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Which of the following should be a standard practice for an organisation using data intermediaries?
Which of the following should be a standard practice for an organisation using data intermediaries?
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What does the Protection Obligation entail for an organisation when engaging a data intermediary?
What does the Protection Obligation entail for an organisation when engaging a data intermediary?
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Which of the following practices should be avoided by data intermediary staff?
Which of the following practices should be avoided by data intermediary staff?
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Study Notes
Key Takeaways from Identifying and Assessing Risks
- Senior management should understand and regularly review risks.
- Identify data protection and information security risks within each department's business processes.
- Assess risks related to data intermediaries and regulatory requirements.
- Establish a baseline of vulnerabilities, gaps, and exposures to data protection risks.
- Escalate key issues to senior management for designing a risk-based DPMP implementation strategy.
Introduction to Risk and Risk Management
- Senior management must understand risks, and regularly review them to consider changes in business models, regulations, technology or other factors.
- Four general categories of risk: financial (processes of the company), strategic (achievement of company objectives), operational (organisation processes), and compliance (legal and ethical).
- Data protection has implications for all four categories.
- Risks for personal data: Confidentiality, Integrity and Availability (CIA). Confidentiality risks are about unauthorised or inappropriate disclosure. Integrity, concerns the risk to the quality and corruption of information. Availability, is about the risk if the data is not available for the intended users.
Risks Relating to the DP and DNC Provisions
- Risks related to non-compliance with the PDPA (Personal Data Protection Act), including meeting eleven obligations and DNC provisions.
- Instances of non-compliance include consent issues, notification issues, purpose limitations, accuracy concerns, retention limitations, protection issues, access and correction problems, transfer limitations, accountability lapses, data portability problems and data breach notifications.
- Example of DNC provisions failure: not checking the relevant DNC registry before sending a marketing message.
Risks Relating to Business Processes
- Risks concerning non-compliance with the PDPA, business processes, third-party vendors and electronic data processing.
- Potential issues relate to whether data collection is authorized, the appropriate level of data collection, sensitive data collection and security, and processes for handling personal data.
- Organisation needs to be aware and to comply with rules and regulations of data handling/ collection/ use/ disposal.
- Key questions to identify gaps: Whether the organisation is collecting more personal data than necessary, whether the data is being processed in a reasonable manner, whether there are any secondary purposes for which personal data is used, and whether personal data is of a sensitive nature.
Risks Relating to Data Intermediaries
- Risks involving third-party vendors or service providers.
- Organizations need to make reasonable security arrangements.
- Failures related to IT systems hacking and data loss or theft of devices containing personal data.
- Contractual issues, insufficient information security controls in the intermediaries IT system, and lack of oversight need to be considered.
Risks Relating to Electronic Processing of Personal Data
- Risks related to electronic data processing include those concerning cyber-security incidents, and personal data breaches.
- Examples: malware attacks, unauthorized access, loss or theft of devices with data, software/program code failures.
The Seven Common Mistakes Made by Organisations
- Insufficient data protection measures.
- Inadequate information or physical security measures.
- Disjointed practices in the organisation, especially between different departments.
- Poor employee training on data protection rules and procedures.
- Lack of oversight of third parties (e.g. data intermediaries).
- Lack of leadership action/complacency on data protection.
- Physical security or data security lapses.
Assessing Measuring Risks and Ranking Them
- Organisation needs to assess the likelihood of a risk occurring and the impact if the risk occurs.
- Use risk assessment frameworks to rate risks.
- Assign numbers (i.e., a likelihood scale and an impact scale) to each risk, which are then multiplied to arrive at a risk ranking score.
Next Steps after Ranking Risks
- The DPO should provide sufficient assistance to the organisation's departments to fulfil requirements for building a data inventory, risk assessment and risk ranking.
- DPO needs to collate and prioritise the risks, and summarise them for senior management's review and approval.
- Senior management need to be involved in the data protection compliance process.
- Engage senior management regularly, and update them about the DPMP's evolution
- Ensure the right level of priority and resources is given to data protection.
- Regular monitoring of personal data protection risks.
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Description
This quiz covers key takeaways from identifying and assessing risks in the context of data protection and risk management. It emphasizes the importance of senior management's role in understanding and reviewing risk categories related to business processes. Assess your knowledge of how to manage risks associated with personal data and the implications for various business operations.