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CISA Practice Question: A multinational corporation's data center in the…
A multinational corporation's data center in the European Union (EU) stores personal data of EU citizens. The company must comply with the General Data Protection Regulation (GDPR), which requires that personal data be protected and that data subjects have the right to erasure ('right to be forgotten'). The company's IT team uses a centralized identity management system that stores user credentials and personal data in an active directory (AD) forest. The AD forest is replicated across multiple data centers worldwide, including a non-EU country. The data protection officer (DPO) is concerned that personal data might be inadvertently replicated to jurisdictions without adequate protection. Which of the following is the most effective way to address this concern?
⚠ Common exam trap
Test-takers frequently confuse encryption (Option B) with data residency, thinking encryption alone prevents data exposure, but encryption does not stop replication and may still allow data to be stored in non-EU jurisdictions where it could be subject to local access laws.
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
✓
Implement data residency controls to ensure EU personal data is only stored and processed within the EU
GDPR mandates that personal data of EU citizens must not be transferred to countries without adequate protection unless specific safeguards are in place. Implementing data residency controls ensures that EU personal data is stored and processed only within the EU, preventing inadvertent replication to non-EU jurisdictions via AD replication. This directly addresses the DPO's concern by enforcing geographic boundaries on data storage and processing.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✗
Pseudonymize all personal data before storing it in AD
Why it's wrong here
Pseudonymization reduces identifiability but data may still be considered personal under GDPR if re-identification is possible.
- ✗
Encrypt all personal data at rest and in transit, with keys held solely within the EU
Why it's wrong here
Encryption with EU-held keys may satisfy data governance but the data still resides elsewhere.
- ✓
Implement data residency controls to ensure EU personal data is only stored and processed within the EU
Why this is correct
Technical controls can enforce geographic boundaries for data replication.
- ✗
Obtain explicit consent from all EU data subjects for international data transfer
Why it's wrong here
Consent is a lawful basis but does not prevent the technical data flow; replication still occurs.
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Written by Johnson Ajibi, MSc IT Security
Senior Network & Security Engineer · founder of Courseiva
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