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CIPP-US: Enhancing Data Privacy and Security Measures to Mitigate Breach Risks

Learn how implementing comprehensive data access policies, secure data storage, and proper data disposal can help companies reduce the risk of data breaches and protect sensitive customer information.

Table of Contents

Question

When there was a data breach involving customer personal and financial information at a large retail store, the company’s directors were shocked. However, Roberta, a privacy analyst at the company and a victim of identity theft herself, was not. Prior to the breach, she had been working on a privacy program report for the executives. How the company shared and handled data across its organization was a major concern. There were neither adequate rules about access to customer information nor procedures for purging and destroying outdated data. In her research, Roberta had discovered that even low-level employees had access to all of the company’s customer data, including financial records, and that the company still had in its possession obsolete customer data going back to the 1980s.

Her report recommended three main reforms. First, permit access on an as-needs-to-know basis. This would mean restricting employees’ access to customer information to data that was relevant to the work performed. Second, create a highly secure database for storing customers’ financial information (e.g., credit card and bank account numbers) separate from less sensitive information. Third, identify outdated customer information and then develop a process for securely disposing of it.

When the breach occurred, the company’s executives called Roberta to a meeting where she presented the recommendations in her report. She explained that the company having a national customer base meant it would have to ensure that it complied with all relevant state breach notification laws. Thanks to Roberta’s guidance, the company was able to notify customers quickly and within the specific timeframes set by state breach notification laws.

Soon after, the executives approved the changes to the privacy program that Roberta recommended in her report. The privacy program is far more effective now because of these changes and, also, because privacy and security are now considered the responsibility of every employee.

What could the company have done differently prior to the breach to reduce their risk?

A. Implemented a comprehensive policy for accessing customer information.
B. Honored the promise of its privacy policy to acquire information by using an opt-in method.
C. Looked for any persistent threats to security that could compromise the company’s network.
D. Communicated requests for changes to users’ preferences across the organization and with third parties.

Answer

A. Implemented a comprehensive policy for accessing customer information.

Explanation

The company could have significantly reduced its risk prior to the breach by implementing a comprehensive policy for accessing customer information (Option A). By restricting employee access to customer data on an as-needed basis, the company would have limited the potential for unauthorized access and misuse of sensitive information. This policy should have been coupled with the creation of a highly secure database for storing customers’ financial information separately from less sensitive data, as well as identifying and securely disposing of outdated customer information.

Establishing clear rules and procedures for data access, storage, and disposal is crucial in preventing data breaches. By ensuring that only authorized personnel have access to specific subsets of customer data relevant to their roles, the company can minimize the risk of unauthorized access and potential misuse. Additionally, segregating highly sensitive financial information in a secure database adds an extra layer of protection, making it more difficult for hackers to access all customer data in the event of a breach.

Furthermore, regularly identifying and securely disposing of outdated customer information helps reduce the amount of data that could be compromised in a breach. This practice not only minimizes the potential impact of a breach but also ensures compliance with data retention regulations.

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