__________ layer of the DSCI Privacy Framework (DPF) ensures that adequate level of awareness exists in an organization.

• A. Personal Information Security
• B. Privacy Strategy and Processes
• C. None of the above
• D. Information Usage, Access, Monitoring and Training

FILL BLANK
PIS
The company has a well-defined and effectively implemented security policy. As in case of access control, the security controls vary in different client relationships based on the client requirements but certain basic or hygiene security practices / controls are implemented organization wide. The consultants have advised the information security function to realign the company's security policy, risk assessment, data classification, etc to include privacy aspects. But the consultants are struggling to make information security function understand what exact changes need to be made and the security function itself is unable to figure it out.
(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.
Can you please guide the information security function to realign company's security initiatives to include privacy protection, keeping in mind that the client security requirements would vary across relationships?
(250 to 500 words)

Which of the following are key contributors that would enhance the complexity in implementing security measures for protection of personal information? (Choose all that apply.)

• A. Data collection through multiple modes and channels
• B. Regulatory requirements to issue privacy notice and data breach notification in specified format
• C. None of the above
• D. Evolution of nimble and flexible business processes affecting access management

Which of the following measures can an organization implement to establish regulatory compliance intelligence? (Choose all that apply.)

• A. Identify the liabilities imposed by the regulations with respect to specific data elements
• B. Establish a process that keeps a track of applicable legal and regulatory changes
• C. Ensure that a mechanism exists for quick and effective provisioning, de-provisioning and authorization of access to information or systems which are exposed to data
• D. Ensure that knowledge with respect to legal and regulatory compliances is managed effectively

Which of the following could be considered as triggers for updating privacy policy? (Choose all that apply.)

• A. Privacy breach
• B. Change in service provider for an established business process
• C. Recruitment of more employees
• D. Regulatory changes