CIPM COMPREHENSIVE EXAM 2026
QUESTIONS WITH SOLUTIONS GRADED A+
◉ Developing Company Vision Steps. Answer: 1) Mission Statement:
short statement (2-4 sentences) regarding why you make the privacy
decisions you do, what it is that you do, show the value placed on
privacy, define objectives, define roles
2) Develop Privacy Program Scope: to develop scope, must identify the
data, sources of data, the law, the information privacy and security
minimum requirements within such law, and the repercussions for
failing to conform
3) Obtain executive sponsorship for program
◉ Primary Concern of In-House Privacy Professional. Answer: Ensure
all law, regs, contractual commitments and industry practices are
followed
◉ Developing Vision>Privacy Program Scope. Answer: 1) Know the
law
2) Know the data
◉ Developing Vision>Privacy Program Scope > Know the Data.
Answer: Think of the organization as a heat map and/or a plumbing
,system. Trying to keep all data within the plumbing without any leaks.
In areas of high PI processing, and an emphasis on areas of sensitive PI
processing, the heatmap becomes more intense.
◉ Developing Vision>Privacy Program Scope > Know the Data > Crazy
8 Questions to Ask Regarding Data Processing to Help Define Privacy
Program Scope. Answer: 1) Where does it come from and who does it
flow to?
2) When is the data collected?
3) What is collected? And how is it collected?
4) Who has access to it? Include third parties.
5) Why is it necessary to have?
6) What is the data being used for?
7) Where is the data stored physically?
8) What are the legal requirements for the data?
◉ Developing Vision > Privacy Program Scope > Know the Data > 6
Legal Questions to Ask to Help Define Program Scope. Answer: 1)
What PI does the law cover?
2) What types of people/companies are covered?
3) What are the privacy or security requirements or prohibitions?
4) Who enforces the law?
5) What are the repercussions for failure to abide?
6) Why does the law exist?
,◉ High-Level statutory information security requirements that can be
found within various U.S. laws. Answer: 1) Infosec program
2) Encryption
3) PI inventory
4) Training
5) "Reasonable infosec"
6) Privacy Officer
7) Breach notice
8) PCI-DSS
9) Authentication
10) Accountability and
11) Data destruction
12) Retention limits
13) Collection limits
14) Incident response plan (DR and BC)
15) Risk assessments
16) Third-party evaluation
17) Physical controls
18) Background checks
19) Contractual protections
, ◉ High-Level statutory information privacy requirements that can be
found within various U.S. laws (11 questiosns). Answer: 1) Privacy
policy
2) Who PI sent to
3) Why and how collected (should include info on cookies, web
beacons, urls, IP addresses, etc.)
4) How it's used
5) Secondary consent for any secondary purpose
6) Description of the data lifecycle: collection, use, purpose, disclosure,
retention, deletion
7) Contract clauses
8) Controls on what minors can do
9) Data breach procedures
10) Privacy awareness/education
11) Data subject asccess, modification, authentication controls
◉ Develop Privacy Program > Set Strategy > Business Alignment >
Steps to Implement. Answer: 1) Develop the business case for privacy
(risk and operational efficiency)
2) Develop data governance strategy
3) Conduct Privacy Workshop
QUESTIONS WITH SOLUTIONS GRADED A+
◉ Developing Company Vision Steps. Answer: 1) Mission Statement:
short statement (2-4 sentences) regarding why you make the privacy
decisions you do, what it is that you do, show the value placed on
privacy, define objectives, define roles
2) Develop Privacy Program Scope: to develop scope, must identify the
data, sources of data, the law, the information privacy and security
minimum requirements within such law, and the repercussions for
failing to conform
3) Obtain executive sponsorship for program
◉ Primary Concern of In-House Privacy Professional. Answer: Ensure
all law, regs, contractual commitments and industry practices are
followed
◉ Developing Vision>Privacy Program Scope. Answer: 1) Know the
law
2) Know the data
◉ Developing Vision>Privacy Program Scope > Know the Data.
Answer: Think of the organization as a heat map and/or a plumbing
,system. Trying to keep all data within the plumbing without any leaks.
In areas of high PI processing, and an emphasis on areas of sensitive PI
processing, the heatmap becomes more intense.
◉ Developing Vision>Privacy Program Scope > Know the Data > Crazy
8 Questions to Ask Regarding Data Processing to Help Define Privacy
Program Scope. Answer: 1) Where does it come from and who does it
flow to?
2) When is the data collected?
3) What is collected? And how is it collected?
4) Who has access to it? Include third parties.
5) Why is it necessary to have?
6) What is the data being used for?
7) Where is the data stored physically?
8) What are the legal requirements for the data?
◉ Developing Vision > Privacy Program Scope > Know the Data > 6
Legal Questions to Ask to Help Define Program Scope. Answer: 1)
What PI does the law cover?
2) What types of people/companies are covered?
3) What are the privacy or security requirements or prohibitions?
4) Who enforces the law?
5) What are the repercussions for failure to abide?
6) Why does the law exist?
,◉ High-Level statutory information security requirements that can be
found within various U.S. laws. Answer: 1) Infosec program
2) Encryption
3) PI inventory
4) Training
5) "Reasonable infosec"
6) Privacy Officer
7) Breach notice
8) PCI-DSS
9) Authentication
10) Accountability and
11) Data destruction
12) Retention limits
13) Collection limits
14) Incident response plan (DR and BC)
15) Risk assessments
16) Third-party evaluation
17) Physical controls
18) Background checks
19) Contractual protections
, ◉ High-Level statutory information privacy requirements that can be
found within various U.S. laws (11 questiosns). Answer: 1) Privacy
policy
2) Who PI sent to
3) Why and how collected (should include info on cookies, web
beacons, urls, IP addresses, etc.)
4) How it's used
5) Secondary consent for any secondary purpose
6) Description of the data lifecycle: collection, use, purpose, disclosure,
retention, deletion
7) Contract clauses
8) Controls on what minors can do
9) Data breach procedures
10) Privacy awareness/education
11) Data subject asccess, modification, authentication controls
◉ Develop Privacy Program > Set Strategy > Business Alignment >
Steps to Implement. Answer: 1) Develop the business case for privacy
(risk and operational efficiency)
2) Develop data governance strategy
3) Conduct Privacy Workshop
