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As a newly appointed Data Protection Officer of an IT company gearing up for DSCI's privacy certification, you are trying to understand what data elements are involved in each of the business process, function and if these data elements can be classified as sensitive personal information. What is being accomplished with this effort?
The described activity directly aligns with the objectives of the ''Visibility over Personal Information (VPI)'' practice area of the DSCI Privacy Framework. VPI involves:
Mapping personal data across all business processes and functions
Identifying whether such data qualifies as personal or sensitive personal information (SPI)
Establishing a baseline understanding of data exposure and privacy risk
This is the first and foundational step in privacy governance to ensure all subsequent controls are accurately targeted.
The objective of DSCI Privacy Assessment Framework -- Organizational Competence of Privacy -- is to assess if the organization is able: (Tick all that apply)
The Organizational Competence aspect of the DSCI Privacy Assessment Framework evaluates whether the organization:
Has structured processes to demonstrate privacy capability (A)
Can offer assurance to stakeholders through effective management systems (B)
Recognizes and supports the privacy framework while seeking improvements (C)
Validates adequacy and effectiveness of privacy safeguards implemented (E)
Meeting all applicable regulations is a result of these capabilities but not the primary focus of the competence assessment layer itself.
What are the Nine Privacy Principles as described in DSCI Privacy Framework (DPF)?
I) Use Limitation
II) Accountability
III) Data Quality
IV) Notice
V) Preventing Harm
VI) Choice and Consent
VII) Access and Correction
VIII) Data Minimization
IX) Openness
X) Disclosure to Third Parties
XI) Right to be Forgotten
XII) Collection limitation
XIII) Security
As per the official DSCI Privacy Framework (DPF), the framework is built upon a set of nine core Privacy Principles that are foundational to establishing and assessing privacy initiatives in an organization. These principles are as follows:
Notice -- Individuals must be informed about the collection and use of their personal data.
Choice and Consent -- The data subject's choice must be respected through consent mechanisms.
Collection Limitation -- Personal data must be collected only for identified purposes.
Use Limitation -- Data should be used only for the purposes specified at the time of collection.
Data Quality -- Ensuring data is accurate, complete, and kept up-to-date.
Access and Correction -- Data subjects must have access to their data and the ability to correct it.
Security -- Adequate protection of personal data against unauthorized access and breaches.
Openness -- Organizations must be transparent about their privacy practices.
Accountability -- The entity collecting and processing data is responsible for complying with the principles.
These match exactly with the components listed in option A: I (Use Limitation), II (Accountability), III (Data Quality), IV (Notice), V (Preventing Harm---not explicitly named in DPF, hence not part of the standard nine), VI (Choice and Consent), VII (Access and Correction), VIII (Data Minimization), IX (Openness).
Hence, the correct nine principles according to DPF are exactly as listed in option A.
Privacy enhancing tools aim to allow users to take one or more of the following actions related to their personal data that is sent to, and used by online service providers, merchants or other users:
I) Increase control over their personal data
II) Choose whether to use services anonymously or not
III) Obtain informed consent about sharing their personal data
IV) Opt-out of behavioral advertising or any other use of data
Privacy Enhancing Tools (PETs), as referenced in the DSCI Privacy Framework and aligned global frameworks, enable users to:
Exercise control over how their personal data is collected, shared, and processed
Use services with the option of anonymity or pseudonymity
Receive sufficient information for informed consent
Opt-out of non-essential data uses such as profiling and behavioral targeting
All the listed actions (I to IV) are valid functions provided by PETs, which support transparency, user control, and minimization of unnecessary data exposure.
Who is a Data Processor?
A Data Processor under the Digital Personal Data Protection Act, 2023 is any entity that processes personal data on behalf of a Data Fiduciary. It does not independently determine the purpose or means of processing but strictly follows the instructions of the Data Fiduciary. Therefore, D is the correct answer.
