CDPSE practice question 10 of 30

Which of the following is the GREATEST concern for an organization subject to cross-border data transfer regulations when using a cloud service provider to store and process data?

Full set: 218 questions
Answer options
A: The service provider has denied the organization’s request for right to audit.
B: Personal data stored on the cloud has not been anonymized.
C: The extent of the service provider’s access to data has not been established.
D: The data is stored in a region with different data protection requirements. Correct answer
Correct Answer:
D. The data is stored in a region with different data protection requirements.
Explanation

The term "cross-border data transfer" directly points to the geographical location of data processing and storage. The greatest regulatory concern, under frameworks like the GDPR, is whether the data is transferred to a jurisdiction with an "adequate" level of data protection. Storing data in a region with different and potentially weaker requirements can result in non-compliance, leading to severe legal and financial penalties. This jurisdictional issue is the most fundamental concern specific to cross-border scenarios.

Why Incorrect

A. The right to audit is a crucial contractual control for vendor oversight but is a general due diligence concern, not one specific to cross-border regulations.
B. Not anonymizing personal data is a general data protection failure, relevant regardless of whether the data transfer is cross-border or domestic.
C. The extent of provider access is a critical access control issue but does not directly address the specific legal requirements governing data movement between countries.

References

1. ISACA, CDPSE Review Manual, 1st Edition, Domain 2: Data Lifecycle, Task 2.5 (Manage data transfer), Knowledge Statement K2.5.1 (Knowledge of cross-border data transfer requirements and mechanisms).

2. General Data Protection Regulation (EU) 2016/679, Chapter V, "Transfers of personal data to third countries or international organisations," Articles 44-50. This chapter explicitly details the legal requirements for transferring data outside the EU.

3. Gellert, R. (2018). Understanding the 'risk-based approach' to data protection. International Data Privacy Law, 8(1), 3-16. https://doi.org/10.1093/idpl/ipx023 (Discusses risk assessment in the context of international transfers).

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