IAPP CIPP-C Exam Dumps & Practice Test Questions

Question 1:

While she agrees with both the accuracy of the diagnosis and the information she gave, she no longer wants others to access it.

Which of the following is the most realistic request the patient can make under Ontario privacy laws?

A. Request to revise the diagnosis based on personal preference
B. Request to limit who can access or view the information
C. Request to keep a copy of the record for her own use
D. Request to have the diagnosis removed from the record

Correct Answer: B

Explanation:

In Ontario, the Personal Health Information Protection Act (PHIPA) governs how health information is collected, used, and shared. It gives patients several rights, including the ability to access and, in specific circumstances, control who can see their personal health data.

In the scenario, the patient acknowledges that the information she shared and the diagnosis she received are both accurate, but she now wishes to control who else can view that information. Under PHIPA, patients have the right to request restrictions on the disclosure of their health information to others—especially healthcare providers—as long as such a restriction does not interfere with the provision of care or legal obligations.

Let’s analyze the choices:

• A. Request to revise the diagnosis based on personal preference
  This request would almost certainly be denied. PHIPA allows corrections to be made to health records only if they are factually inaccurate or incomplete. Since the diagnosis is medically valid and undisputed, changes cannot be made simply because the patient is uncomfortable with it.

• B. Request to limit who can access or view the information
  This is the most appropriate and likely to be granted. PHIPA gives patients the ability to place “lockbox” restrictions on their health records, limiting access by specific providers or institutions. However, exceptions apply if the information is required for direct care or if legal mandates override the patient’s request.

• C. Request to keep a copy of the record for her own use
  While patients are entitled to obtain copies of their health records, this action does not limit disclosure to others. It simply gives the patient access to the same information but does nothing to restrict its visibility within the healthcare system.

• D. Request to remove the diagnosis from the record
  Health records must reflect an accurate and complete history of care. Deletion of valid medical information is not allowed unless it’s factually incorrect. Therefore, this request is incompatible with PHIPA’s guidelines on record integrity.

In conclusion, requesting to restrict access is the most feasible option. While the diagnosis remains on the record, the patient has some control over who may see it, provided it does not conflict with care needs or the law.

Question 2:

Under the Government of Canada’s Directive on Privacy Impact Assessments (PIAs), which of the following entities is not required to comply with this directive?

A. The federal Ministry of Health
B. The Bank of Canada
C. A Crown Corporation
D. The Cabinet

Correct Answer: D

Explanation:

The Directive on Privacy Impact Assessments (PIAs) is a federal policy under the Government of Canada, designed to ensure that government institutions assess potential privacy risks when initiating any new project, program, or technology that involves the handling of personal information. The objective is to ensure compliance with the Privacy Act and protect individual privacy through proactive risk identification and mitigation.

Let’s evaluate each option to determine which entity falls outside the scope of this directive:

• A. The Ministry of Health
  This federal department is responsible for national health-related policies and initiatives. As a government institution, it must comply with the PIA directive when developing programs that collect or use personal health data. Any project involving personal information would require a PIA to assess and minimize privacy risks.

• B. The Bank of Canada
  As a Crown Corporation, the Bank of Canada is a government-owned entity that plays a critical role in national financial policy. Although it operates at arm's length from the government, it is still considered part of the federal public sector and therefore must follow government directives, including PIAs.

• C. Crown Corporations
  These organizations, even though they function independently in many respects, are subject to the Privacy Act and related privacy policies. When developing systems that process personal data, Crown Corporations are obligated to conduct Privacy Impact Assessments under the directive.

• D. The Cabinet
  This is the correct answer. The Cabinet refers to the executive decision-making body composed of the Prime Minister and ministers. It does not operate in the same capacity as departments or agencies that run programs involving personal information. As such, the Cabinet is not bound by the Directive on PIAs. It doesn’t directly administer services or collect personal data in the way that operational departments or Crown Corporations do. Therefore, it is exempt from the requirement to conduct PIAs.

In summary, all operational government institutions and agencies, including ministries and Crown Corporations, must adhere to the PIA directive. The Cabinet, serving more as a decision-making and executive authority, is not subject to this requirement.

Question 3:

Which of the following scenarios is most clearly governed by the Personal Information Protection and Electronic Documents Act (PIPEDA)?

A. Personal data collected by a private organization for creative or journalistic activities
B. Health-related personal data managed by private-sector entities in provinces with equivalent privacy legislation
C. Personal data transferred across provincial or national boundaries by entities like list brokers or credit bureaus
D. Business-related contact details such as names, roles, and email addresses used internally for employee communication

Correct Answer: C

Explanation:

The Personal Information Protection and Electronic Documents Act (PIPEDA) is a Canadian federal privacy law that regulates how private-sector businesses collect, use, and disclose personal information during commercial activities. Its primary goal is to protect individuals' privacy while allowing organizations to use personal data responsibly for business operations. PIPEDA applies across Canada unless a province has enacted similar legislation deemed "substantially similar."

Among the four options, Option C—the disclosure of personal information across provincial or national borders—is most clearly subject to PIPEDA. This includes situations where organizations such as credit bureaus, list marketers, or commercial data brokers transfer personal data for commercial purposes between provinces or outside of Canada. In such cases, PIPEDA ensures that individuals’ data continues to receive adequate protection, even when it leaves its original jurisdiction.

Let’s analyze why the other options do not fall under PIPEDA’s jurisdiction:

• A. Personal information collected for journalistic or artistic purposes is specifically exempt under PIPEDA. These activities are excluded to safeguard freedom of expression. As such, journalists, artists, and writers are not bound by PIPEDA when collecting personal data for their creative or journalistic work.

• B. Health data processed by private companies in provinces with equivalent laws (e.g., Alberta, British Columbia, Quebec) falls under provincial legislation. PIPEDA defers to provincial health privacy laws when they meet or exceed its standards. So in these regions, PIPEDA does not govern personal health information managed by private health service providers.

• D. Professional contact details used for employment-related communication are typically not protected under PIPEDA. Information like names, titles, and work contact details used to communicate with employees in a business context is excluded when not connected to commercial transactions or consumer data handling.

Therefore, Option C represents a situation in which PIPEDA directly applies. The act governs the inter-provincial or international flow of personal data for commercial reasons, ensuring consistent standards of privacy protection regardless of geographic boundaries.

Question 4:

Under PIPEDA, when a company transfers personal data to a third-party processor—especially across borders—which requirement must the organization meet in addition to securing the data during transit?

A. Draft a formal outsourcing contract detailing the arrangement
B. Obtain new consent from the individual for third-party processing
C. Verify that the destination jurisdiction offers privacy protections equivalent to PIPEDA
D. Submit the data transfer for approval by the Treasury Board of Canada Secretariat

Correct Answer: C

Explanation:

The Personal Information Protection and Electronic Documents Act (PIPEDA) outlines specific obligations for organizations that handle and transfer personal information, especially when outsourcing processing to third parties, whether domestic or international. One critical requirement in these circumstances is that the original data-handling organization must ensure continued protection of personal data, even when the processing is delegated.

Option C accurately reflects this requirement. Organizations are expected to assess the privacy standards in the third party’s jurisdiction to ensure they are comparable to those outlined in PIPEDA. If the data is sent to a location where legal privacy protections are inadequate, the organization must implement contractual or technological safeguards to compensate for this discrepancy. The goal is to ensure that personal information remains protected no matter where it is processed.

Let’s consider why the other options are not correct:

• A. Drafting a formal outsourcing contract is considered a best practice, but PIPEDA does not explicitly require a written contract for each third-party transfer. However, contracts are a common mechanism to enforce the third party’s compliance with privacy obligations. Even though important, a contract alone does not fulfill the requirement to assess jurisdictional equivalence.

• B. Seeking additional consent is unnecessary when the data is transferred solely for processing purposes, and the original consent covers the intended use. According to PIPEDA, transferring data to a processor does not require renewed consent, provided the processor acts strictly on behalf of the data controller and within the scope of original authorization.

• D. Involving the Treasury Board of Canada Secretariat is not part of the PIPEDA framework for third-party processing. This federal body is not responsible for approving cross-border data transfers in the private sector. Organizations are independently responsible for ensuring legal compliance.

In conclusion, the correct PIPEDA requirement is for organizations to evaluate the data protection laws of the third party’s location and ensure equivalency with Canadian standards. If discrepancies exist, appropriate measures must be taken to ensure personal data is secure and handled responsibly, even outside Canadian borders.

Question 5:

Under Canada’s Privacy Act, in which of the following cases must a government institution obtain an individual’s consent before disclosing their personal information?

A. Sharing the information with law enforcement authorities
B. Releasing the information as required by a search warrant
C. Providing the information to a registered charitable organization
D. Sending the information to a Member of Parliament assisting with an issue

Correct Answer: C

Explanation:

Canada’s Privacy Act governs the collection, use, and disclosure of personal information by federal government institutions. Its primary purpose is to protect individuals' privacy while allowing institutions to carry out their mandated responsibilities. The general principle is that personal information should not be shared without the individual’s consent, unless a specific exception is clearly outlined in the Act.

Let’s review each option to determine which situation requires consent:

A. Disclosing to a law enforcement agency is a recognized exception in the Privacy Act. When the release of personal information is necessary for law enforcement purposes such as the investigation or enforcement of Canadian laws, the Act allows it without requiring consent from the individual. This ensures that law enforcement bodies can act swiftly without privacy barriers during investigations.

B. When complying with a search warrant, disclosure is legally mandated. A search warrant is a judicial instrument that authorizes government institutions to release certain information. Since it is required by law, consent from the individual is not necessary in this case. Legal obligations override the usual requirement for individual authorization.

C. Disclosing personal information to a registered charitable organization is not covered by any of the exceptions in the Privacy Act. There is no provision that allows government institutions to freely share data with charities unless the individual has provided explicit consent. Since these organizations are not governmental entities or mandated service providers, their access to personal information is restricted unless the person agrees.

D. Sharing information with a Member of Parliament (MP) for the purpose of assisting a constituent is permitted under the Privacy Act. The law provides an exception for this scenario, recognizing that MPs often act on behalf of citizens in resolving issues with government services. As such, disclosing personal information in these cases does not require the individual’s consent.

In summary, among all the options, the only instance where consent is strictly required is when personal information is being shared with a charitable organization. This is because the Privacy Act does not list such disclosures among its authorized exceptions.

Question 6:

According to Canada’s PIPEDA law, which of the following would not be classified as personal information?

A. The published salary of a public official on a government website
B. A phone number listed in a publicly accessible directory
C. A photograph of a person taken in a public space and featured in a news article
D. Legal details about a defendant included in publicly available court documents

Correct Answer: A

Explanation:

The Personal Information Protection and Electronic Documents Act (PIPEDA) is Canada’s federal law governing the collection, use, and disclosure of personal information in commercial settings. It defines personal information as any data about an identifiable individual, such as names, photos, or financial details. However, publicly available data—especially when tied to professional or official roles—may fall outside the scope of this definition.

Let’s assess each option based on PIPEDA’s criteria:

A. A public official’s salary posted on a government website is not considered personal information under PIPEDA. This is because the individual is acting in a public role, and the disclosure of their salary is part of government transparency. The information is made available to the public in an official capacity, and as such, it is excluded from protection under PIPEDA. This makes option A the correct answer, as it does not meet the standard for protected personal information.

B. A telephone number listed in a public directory can still be considered personal information. Even if publicly accessible, it identifies an individual and relates to their personal contact details. PIPEDA does make exceptions for publicly available information where the individual has consented to publication—such as opting to list a number in a phonebook—but it still qualifies as personal information in context.

C. A photograph taken in a public setting and published in a newspaper also qualifies as personal information if the individual can be identified. Even though it occurs in a public space, the image captures aspects of a person’s identity. However, if used for journalistic purposes, PIPEDA may not apply due to the journalism exemption, but the data itself still qualifies as personal information.

D. Information about a defendant in public court records is also considered personal information. However, because court records are generally public, such disclosures are permitted for reasons of transparency and public interest. While PIPEDA does not apply to publicly accessible court records, the data itself remains identifiable and personal in nature.

In conclusion, only Option A—a public official’s government-posted salary—does not qualify as personal information under PIPEDA.

Question 7:

What is the most effective way for a person to determine whether the federal government has used their personal information for data matching purposes?

A. Sending written inquiries to third parties conducting data matching on behalf of the government
B. Reviewing descriptions of Personal Information Banks listed in Info Source
C. Recommending a Privacy Impact Assessment (PIA) within the relevant government institution
D. Checking the Privacy Commissioner of Canada’s annual report

Correct Answer: B

Explanation:

To ensure transparency in how personal information is handled, the Canadian federal government is legally required to maintain a clear record of its data collection, use, and sharing practices. Under the Privacy Act, one of the main tools used to achieve this transparency is the system of Personal Information Banks (PIBs). These are official repositories that describe in detail how personal information is collected and managed by various federal departments and agencies.

Option A, suggesting that an individual write directly to third-party contractors performing data matching for the government, is not the correct approach. Private contractors or third parties are not legally obligated to respond directly to individuals. Instead, requests about how personal data is used should go through the relevant federal institution, which is accountable under the Privacy Act.

Option B is the correct answer. Info Source is a government-maintained directory that includes descriptions of all Personal Information Banks held by federal departments. Each PIB includes details such as the purpose for collecting information, how it is used, with whom it may be shared (including for data matching), and under what legislative authority. By searching Info Source, individuals can verify whether a specific government department holds their information and whether it might be involved in data matching programs. This is the most direct, transparent, and user-accessible method to understand how personal data is being processed.

Option C refers to a Privacy Impact Assessment (PIA), which is a formal tool used by federal departments to evaluate the privacy risks of new programs or technologies that involve personal data. However, these assessments are initiated and completed by the institution itself—not by individuals. Citizens cannot propose or enforce the completion of a PIA.

Option D involves reviewing the Privacy Commissioner’s annual report, which summarizes broad privacy trends, investigations, and systemic issues across Canada. While useful for understanding overall practices, the report does not provide case-specific information about how an individual’s personal data was used.

In summary, if someone wants to determine whether their personal information is being used for data matching by the federal government, the most reliable and accessible method is to review the detailed PIB entries published in Info Source.

Question 8:

According to Ontario’s Personal Health Information Protection Act (PHIPA), which of the following organizations is not allowed to use the implied consent model for handling personal health information?

A. Private insurance providers
B. Long-term care facilities
C. Ambulance services
D. Community pharmacies

Correct Answer: A

Explanation:

The Personal Health Information Protection Act (PHIPA) governs the collection, use, and sharing of personal health information (PHI) in Ontario. It outlines strict rules that apply to health information custodians, which include doctors, hospitals, clinics, pharmacies, ambulance services, and long-term care homes. One key aspect of PHIPA is the implied consent model, which allows certain custodians to share and use health data within the circle of care without needing explicit permission in each instance.

Let’s evaluate each option to determine who may or may not rely on implied consent.

Option A, private insurance companies, is the correct answer because they are not considered health information custodians under PHIPA in the same way healthcare providers are. Since they are typically not part of the patient’s direct circle of care, they are required to obtain explicit consent from individuals before collecting, using, or disclosing their health information. This is critical in protecting patient data from unauthorized use in non-clinical contexts, such as insurance underwriting or claims processing.

Option B, long-term care homes, are included in PHIPA’s definition of health information custodians. They are permitted to rely on implied consent when handling personal health information for treatment, care, and service delivery. This is considered reasonable because the health information is used directly for the benefit of the individual under their care.

Option C, ambulance services, also fall under the umbrella of healthcare providers. In emergency situations, where explicit consent is impractical or impossible, implied consent is essential and expected. It allows paramedics and emergency medical teams to share necessary health information with hospitals and other healthcare providers to ensure proper care.

Option D, pharmacies, are directly involved in delivering health services. When a person submits a prescription, it is understood that their personal health information will be used to process and dispense medication. Therefore, implied consent applies here as well. However, pharmacies must still obtain explicit consent for non-care-related uses like marketing.

In conclusion, only private insurance companies cannot use implied consent under PHIPA. They must request clear and documented permission before accessing or using an individual's personal health information for any reason. This legal safeguard ensures that sensitive health data remains confidential and is only used with full awareness and permission from the individual.

Question 9:

Under which circumstance can the Office of the Privacy Commissioner of Canada escalate a matter to the federal court system?

A. To resolve disputes concerning privacy violations tied to the Canadian Charter of Rights and Freedoms
B. To determine whether personal information was rightfully or wrongfully withheld from an individual
C. To review a decision made by an administrative body related to privacy issues
D. To appeal a ruling made by a provincial Privacy Commissioner

Correct Answer: B

Explanation:

The Privacy Commissioner of Canada is responsible for overseeing the application of federal privacy legislation, such as the Privacy Act and PIPEDA (Personal Information Protection and Electronic Documents Act). These laws regulate how federal institutions and private organizations handle personal information. While the Commissioner’s role is largely advisory and investigative, they can, under specific conditions, initiate legal proceedings in federal court.

Let’s examine each option:

A. Disputes under the Canadian Charter of Rights and Freedoms
While the Charter guarantees privacy-related rights, issues arising directly under the Charter—such as unlawful search or seizure—are adjudicated by the courts, not by the Privacy Commissioner. The Commissioner has no authority to launch court proceedings purely based on Charter concerns. These matters are constitutional in nature and typically handled by legal counsel, not administrative bodies like the Office of the Privacy Commissioner.

B. Whether personal information was rightfully withheld
This is the correct answer. If a person makes a request to access their personal information held by a federal institution or private organization, and that request is denied, the individual can file a complaint with the Privacy Commissioner. If the organization refuses to comply with the Commissioner’s recommendations or if the issue remains unresolved, the Commissioner may escalate the matter to the Federal Court. In such cases, the court evaluates whether the refusal to disclose the requested personal information was lawful. This is a central legal authority granted to the Commissioner.

C. Rulings by administrative tribunals
Administrative tribunals handle specialized areas of law, and while their rulings may impact privacy, the Privacy Commissioner does not have jurisdiction to challenge such rulings in court unless they relate specifically to noncompliance with privacy laws. Therefore, this is not a situation where the Commissioner would proceed to federal court.

D. Provincial Privacy Commissioner rulings
Canada’s privacy governance is divided between federal and provincial jurisdictions. Each province and territory may have its own privacy commissioner with authority over local matters. The federal Privacy Commissioner cannot appeal or challenge decisions made by their provincial counterparts.

In conclusion, the Privacy Commissioner of Canada is legally empowered to go to federal court to seek a ruling when there's a dispute over whether personal information was properly withheld. This ensures compliance and reinforces the public’s right to access their own personal data.

Question 10:

Why is it most important for a federal government department or agency to complete a Privacy Impact Assessment (PIA)?

A. To support the process of proposing new legislation in Parliament
B. To secure program approvals from the Treasury Board of Canada
C. To receive expert analysis from the Office of the Privacy Commissioner
D. To enhance personal data collection through technology upgrades

Correct Answer: B

Explanation:

A Privacy Impact Assessment (PIA) is a proactive risk management tool used by Canadian federal departments and agencies to ensure that privacy protections are built into any initiative that involves the collection, use, or disclosure of personal information. Completing a PIA is often a mandatory step in the project approval process, especially when dealing with programs that manage sensitive or identifiable information.

Let’s evaluate the options:

A. Supporting new legislation in Parliament
While new laws may affect privacy, completing a PIA is not directly tied to the legislative process. PIAs are operational tools used by departments to assess privacy risks in specific projects or systems, not laws. Legislators are not required to complete PIAs before introducing bills, although privacy implications may be considered in policy development.

B. Receiving program approvals from the Treasury Board of Canada
This is the correct answer. The Treasury Board Secretariat (TBS) requires federal entities to complete a PIA as part of its Directive on Privacy Practices. Before a new or modified program involving personal data can move forward, especially those requesting funding or strategic approval, a PIA must be submitted. It ensures that privacy risks have been assessed and that mitigation strategies are in place. This process aligns with both the Privacy Act and internal government privacy policies. Therefore, the PIA plays a critical role in obtaining necessary approvals from the Treasury Board.

C. Receiving expertise from the Privacy Commissioner
While the Office of the Privacy Commissioner may review completed PIAs and offer guidance, that is not the main reason they are conducted. The Privacy Commissioner does not grant approvals or certify PIAs. The process is primarily internal, driven by Treasury Board requirements. Hence, this is not the principal motivation behind conducting a PIA.

D. Improving IT-based data collection systems
While a PIA might uncover flaws in how personal data is collected or handled—prompting IT upgrades—this is a secondary benefit, not the primary goal. The main purpose is to evaluate and reduce privacy risks, not to optimize technical systems for efficiency.

In summary, a Privacy Impact Assessment ensures that privacy concerns are addressed before a new government program involving personal data is approved. It is a requirement for obtaining Treasury Board authorization, making option B the most accurate and appropriate choice.