100% Free IAPP CIPP-C Practice Test Questions

Question 1

SCENARIO

Please use the following to answer the next QUESTION:

You are the chief privacy officer at HealthCo, a major hospital in a large U.S. city in state A. HealthCo is a

HIPAA-covered entity that provides healthcare services to more than 100,000 patients. A third-party cloud

computing service provider, CloudHealth, stores and manages the electronic protected health information

(ePHI) of these individuals on behalf of HealthCo. CloudHealth stores the data in state B. As part of

HealthCo’s business associate agreement (BAA) with CloudHealth, HealthCo requires CloudHealth to

implement security

measures, including industry standard encryption practices, to adequately protect the data. However, HealthCo

did not perform due diligence on CloudHealth before entering the contract, and has not conducted audits of

CloudHealth’s security measures.

A CloudHealth employee has recently become the victim of a phishing attack. When the employee

unintentionally clicked on a link from a suspicious email, the PHI of more than 10,000 HealthCo patients was

compromised. It has since been published online. The HealthCo cybersecurity team quickly identifies the

perpetrator as a known hacker who has launched similar attacks on other hospitals – ones that exposed the PHI

of public figures including celebrities and politicians.

During the course of its investigation, HealthCo discovers that CloudHealth has not encrypted the PHI in

accordance with the terms of its contract. In addition, CloudHealth has not provided privacy or security

training to its employees. Law enforcement has requested that HealthCo provide its investigative report of the

breach and a copy of the PHI of the individuals affected.

A patient affected by the breach then sues HealthCo, claiming that the company did not adequately protect the

individual’s ePHI, and that he has suffered substantial harm as a result of the exposed data. The patient’s

attorney has submitted a discovery request for the ePHI exposed in the breach.

What is the most significant reason that the U.S. Department of Health and Human Services (HHS) might

impose a penalty on HealthCo?

A : Because HealthCo did not require CloudHealth to implement appropriate physical and administrativemeasures to safeguard the ePHI

B : Because HealthCo did not conduct due diligence to verify or monitor CloudHealth’s security measures

C : Because HIPAA requires the imposition of a fine if a data breach of this magnitude has occurred

D : Because CloudHealth violated its contract with HealthCo by not encrypting the ePHI

Answer: B

Question 2

Which of the following best describes an employer’s privacy-related responsibilities to an employee who has

left the workplace?

A : An employer has a responsibility to maintain a former employee’s access to computer systems andcompany data needed to support claims against the company such as discrimination.

B : An employer has a responsibility to permanently delete or expunge all sensitive employment records tominimize privacy risks to both the employer and former employee.

C : An employer may consider any privacy-related responsibilities terminated, as the relationship betweenemployer and employee is considered primarily contractual.

D : An employer has a responsibility to maintain the security and privacy of any sensitive employmentrecords retained for a legitimate business purpose.

Answer: B

Question 3

What important action should a health care provider take if the she wants to qualify for funds under the Health Information Technology for Economic and Clinical Health Act (HITECH)?

A : Make electronic health records (EHRs) part of regular care

B : Bill the majority of patients electronically for their health care

C : Send health information and appointment reminders to patients electronically

D : Keep electronic updates about the Health Insurance Portability and Accountability Act

Answer: A

Question 4

Which of the following types of information would an organization generally NOT be required to disclose to

law enforcement?

A : Information about medication errors under the Food, Drug and Cosmetic Act

B : Money laundering information under the Bank Secrecy Act of 1970

C : Information about workspace injuries under OSHA requirements

D : Personal health information under the HIPAA Privacy Rule

Answer: D

Question 5

SCENARIO

Please use the following to answer the next QUESTION:

A US-based startup company is selling a new gaming application. One day, the CEO of the company receives

an urgent letter from a prominent EU-based retail partner. Triggered by an unresolved complaint lodged by an

EU resident, the letter describes an ongoing investigation by a supervisory authority into the retailer’s data

handling practices.

The complainant accuses the retailer of improperly disclosing her personal data, without consent, to parties in

the United States. Further, the complainant accuses the EU-based retailer of failing to respond to her

withdrawal of consent and request for erasure of her personal data. Your organization, the US-based startup

company, was never informed of this request for erasure by the EU-based retail partner. The supervisory

authority investigating the complaint has threatened the suspension of data flows if the parties involved do not

cooperate with the investigation. The letter closes with an urgent request: “Please act immediately by

identifying all personal data received from our company.”

This is an important partnership. Company executives know that its biggest fans come from Western Europe;

and this retailer is primarily responsible for the startup’s rapid market penetration.

As the Company’s data privacy leader, you are sensitive to the criticality of the relationship with the retailer.

Upon review, the data privacy leader discovers that the Company’s documented data inventory is obsolete.

What is the data privacy leader’s next best source of information to aid the investigation?

A : Reports on recent purchase histories

B : Database schemas held by the retailer

C : Lists of all customers, sorted by country

D : Interviews with key marketing personnel

Answer: C

Free Practice IAPP CIPP-C Exam Questions 2025