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A project manager for a new data collection system had a privacy impact assessment (PIA)...

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A project manager for a new data collection system had a privacy impact assessment (PIA) completed before the solution was designed. Once the system was released into production, an audit revealed personal data was being collected that was not part of the PIA What is the BEST way to avoid this situation in the future?

A.

Conduct a privacy post-implementation review.

B.

Document personal data workflows in the product life cycle

C.

Require management approval of changes to system architecture design.

D.

Incorporate privacy checkpoints into the secure development life cycle

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