What Should Trigger a Review of an Organization's Privacy Policy?
Short answer
D The privacy steering committee adopts a new charter.
Question
Key Takeaways
This question tests the difference between a data-processing change and an internal governance event; a privacy steering committee charter change (D) is a governance event, not a direct trigger for reviewing the public-facing privacy policy.
In CDPSE, you must identify which events require updating the privacy policy. The consensus from IT professionals is that implementing an emerging technology (C) is the best trigger because it affects how personal data is collected and processed.
Common mistake: Selecting D, 'the privacy steering committee adopts a new charter,' is a common trap because candidates confuse the committee's internal charter with the organization's privacy policy; changing a governance document does not by itself alter the organization's personal data practices.
Expert Analysis
Why the Answer Is Correct
C is correct because implementing an emerging technology can change the way the organization collects, uses, stores, or shares personal information. These changes create new privacy risks and disclosure obligations, so the privacy policy must be reviewed and updated to remain accurate and compliant.
Why the Other Options Are Wrong
A is not necessarily a trigger because routine changes to backup procedures do not automatically affect the privacy policy unless they alter data retention, storage location, or third-party processing. B is an operational issue that indicates control weaknesses, but increased DLP incidents is not a direct reason to revise the privacy policy. D is a governance change that may affect the privacy program's internal structure, but it does not by itself change the organization's data handling or what the policy must disclose.
Community Comment Notes
Several commenters correctly point to C, explaining that new technology often introduces new ways of collecting, processing, or storing data and therefore requires a privacy policy update. One commenter defends D, but without a strong rationale: adopting a steering committee charter is separate from revising the external privacy policy. The most useful comments support C by focusing on the impact new technology has on data-handling practices.
Official Reference
- https://www.isaca.org/credentialing/cdpse
- https://www.isaca.org/credentialing/cdpse/cdpse-exam-content-outline
- https://www.nist.gov/privacy-framework
These links open the official vendor documentation in a new tab.
Exam Strategy
When a CDPSE question asks what should trigger a privacy policy review, look for the event that changes actual personal data processing, such as new technology, new processes, or new data sharing. Avoid picking options that only change internal governance documents or metrics unless the question explicitly says they affect the privacy notice.
Community Votes
100% of anonymous learners picked answer D. Votes are pick records left by other test-takers — they are not the verified answer.
Discussion 3 contributions
Compiled from public community threads and reader submissions, lightly edited for clarity. Handles and vote tallies are shown as recorded, and comments reflect the views of individual contributors.
From public community threads 3
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821bbab 👍 1My answer is C. The implementation of an emerging technology should trigger a review of an organization’s privacy policy, as new technologies often introduce new ways of collecting, processing, or storing data, which can impact privacy practices. Reviewing the privacy policy in such cases ensures it reflects current data-handling practices and complies with relevant regulations. While the privacy steering committee adopts a new charter may impact internal governance but does not directly necessitate changes to the privacy policy.
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4dfe785 👍 1 Answered DGiven answer is correct. - D. The privacy steering committee adopts a new charter.
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shiowbah 👍 1C. An emerging technology will be implemented.
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