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CAS-004 Practice Question: A multinational organization is subject to GDPR…

A multinational organization is subject to GDPR and local data protection laws. A data subject from country X requests deletion of personal data, but the data is also required for a legal hold under country Y's law. What is the BEST course of action?

⚠ Common exam trap

It's easy for candidates to assume GDPR always takes precedence over local laws, but CompTIA tests the understanding that conflicting legal obligations require retaining the data and notifying the data subject, not automatically deleting or escalating.

Answer choices

Why each option matters

Answer the question above first, then reveal the full breakdown to understand why each option is right or wrong.

Correct answer & explanation

Retain the data and inform the data subject of the conflicting legal obligation

When a legal hold under country Y's law conflicts with a GDPR deletion request, the organization must retain the data to comply with the legal obligation and inform the data subject of the conflicting legal requirement. GDPR Article 17(3)(e) explicitly allows retention when necessary for compliance with a legal obligation under Union or Member State law. This balances the data subject's right to erasure with overriding legal holds, which are common in e-discovery and litigation scenarios.

Answer analysis

Option-by-option breakdown

For each option: why learners choose it and why it is or isn't the right answer here.

  • Anonymize the data to satisfy both requirements

    Why it's wrong here

    Anonymization may not satisfy the legal hold.

  • Escalate to the data protection authority

    Why it's wrong here

    Escalation is premature without first informing the data subject.

  • Retain the data and inform the data subject of the conflicting legal obligation

    Why this is correct

    This balances compliance requirements transparently.

  • Delete the data to comply with GDPR

    Why it's wrong here

    Deletion would violate the legal hold requirement.

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Written by Johnson Ajibi, MSc IT Security

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