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DSCI Certified Privacy Lead Assessor DCPLA certification Sample Questions:

1. FILL BLANK
VPI
As a starting point, the consultants undertook a visibility exercise to understand the type of personal information (PI) being dealt with within the organization and also by third parties and the scope was to cover all the client relationships (IT services and BPM both) and functions. They met with the client relationship and business function owners to collect this data. The consultants did a mapping exercise to identify PI and associated attributes including whether company directly collects the PI, how it is accessed, transmitted, stored and what are the applicable regulatory and contractual requirements. Given the enormous scale of the exercise (enterprise wide), the consultant classified the PI as financial information, health related information, personally identifiable information, etc. and collected the rest of the attributes against this classification.
When understanding the underlying technology environment, the consultants restricted themselves only to the technology environment that was under company's ownership and premises and did not continue the exercise for client side environment. This was done because relationship owners seemed reluctant to share such client specific details. Only in 2 relationships, were the relationship heads proactive to introduce the consultants to the clients and get the requisite information. The analysis of the environment in these 2 relationships revealed that even though lots of restrictions were imposed at the company side, the same restrictions were not available at the client side.
Many business functions were also availing services from third party service providers. Though these functions were aware of the type of PI dealt by third parties, they were not aware of the technology environment at the third parties. In one odd case, personal information of a company employee was accidentally leaked by the employee of the third party through the social networking site. The consultants relied on whatever information was provided by the functions w.r.t. third parties. After finishing the data collection, the consultant used the information to create information flow maps highlighting the flow of information across systems deployed at the company premises. This work helped them have a high level view of PI dealt by the company. The data collection exercise has been conducted only once by the consultants.
The visibility exercise empowered the management to have a company-wide view of PI and how it flows across the organization. This information was coupled with the security controls / practices deployed at the relationship or function level to derive the risk posture of the PI.
(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.
Was the visibility exercise adequately carried out? What gaps did you notice? (250 to 500 words)

2. What are the two phases of DSCI Privacy Third Party Assessment?

A) None of the above
B) Initial and Detailed
C) Initial and Final
D) Primary and Secondary

3. FILL BLANK
RCI and PCM
In April 2011, the rules were issued under Section 43A of the IT Act by the Government of India and the
'body corporates' were required to comply with these rules. The Corporate legal team tried to understand and interpret the rules but struggled to understand its applicability esp. to client relationships and business functions. So, the company hired an IT Act legal expert to advise them on the Section 43A rules.
To start with, the company identified the PI dealt with by business functions as part of the earlier visibility exercise, but it wanted to reassure itself. Therefore, a specific exercise was conducted to revisit 'sensitive personal information' dealt by business functions. It was realized that the company collects lot of SPI of its employees and therefore 'reasonable security practices' need to be adhered to by the functions that deal with SPI. It was also ascertained that many of this SPI is being dealt by third parties, some of which are also located outside India. To meet the requirements of the rules, the company reviewed all the contracts and inserted a clause - 'the service provider shall implement reasonable security practices and procedures as per the IT (Amendment) Act, 2008'. Some of the large service providers were ISO 27001 certified and they claimed that they fulfill the requirements of 'reasonable security practices'. However, some SME service providers did not understand what would 'reasonable security practices' imply and requested the company to clarify, which referred them to Rule 8 of the Section 43A. Some small scale service providers expressed their unwillingness to get ISO certified, given the costs involved.
(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.
Did the company take sufficient steps to protect SPI dealt by its service providers and ensure that it complies with the regulatory requirements? Was referring to 'reasonable security practices' sufficient in the contracts or the company should have also considered some other measures for privacy protection as well? (250 to 500 words)

4. What is the maximum penalty amount for Data Principals for breach of their duties under Section-15 of the Digital Personal Data Protection Act, 2023?

A) Upto 50 crore rupees
B) Upto 200 crore rupees
C) Upto 10 thousand rupees
D) Upto 250 crore rupees

5. Classify the following scenario as major or minor non-conformity.
"The organization has a very mature information security policy. Lately, the organization has realized the need to focus on protection of PI. A formal PI identification exercise was done for this purpose and a mapping of PI and security controls was done. The organization has also put in place data masking technology in certain functions where the SPI was accessed by employees of a third party. However, the organization is yet to include PI specifically in its risk assessment exercise, incident management, testing, data classification and security architecture programs."

A) None of the above
B) Major
C) Both Major and Minor
D) Minor

Solutions: