- A
A data protection impact assessment (DPIA) approved by the local supervisory authority.
Why wrong: A DPIA is a process to assess risk but is not a transfer mechanism; it may be required in addition to SCCs.
- B
Standard Contractual Clauses (SCCs) adopted by the European Commission.
SCCs are a ready-to-use mechanism that provides contractual guarantees of adequate protection for cross-border data transfers.
- C
Explicit consent from each data subject for the transfer.
Why wrong: Consent can be withdrawn and is not considered a reliable long-term transfer mechanism under GDPR.
- D
Binding Corporate Rules (BCRs) for intra-group transfers.
Why wrong: BCRs are valid for intra-group transfers but require lengthy approval from multiple authorities; SCCs are more common for simpler arrangements.
Quick Answer
The answer is Standard Contractual Clauses (SCCs) adopted by the European Commission. This mechanism is most commonly accepted because SCCs are pre-approved model contracts that impose binding data protection obligations on both the EU data exporter and the US importer, satisfying GDPR Article 46’s requirement for adequate safeguards without needing separate regulatory approval. On the CISA exam, this question tests your understanding of lawful transfer mechanisms under GDPR, often appearing in scenarios involving multinational data flows where the US lacks an adequacy decision. A common trap is confusing SCCs with Binding Corporate Rules (BCRs), which apply to intra-group transfers but require more complex approval. Remember the memory tip: “SCCs are the standard shortcut for cross-border compliance.”
CISA Protection of Information Assets Practice Question
This CISA practice question tests your understanding of protection of information assets. Match the stated requirement to the specific cloud service, access model, or configuration option — many options are valid in isolation but not for this scenario. After answering, compare your reasoning against the explanation and wrong-answer breakdown below. Once you have made your selection, read the full explanation to reinforce the concept and understand why each distractor is designed to mislead on exam day.
A multinational company must comply with GDPR and local data protection laws when transferring personal data from the EU to a subsidiary in the US. Which transfer mechanism is most commonly accepted as providing adequate protection?
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
Standard Contractual Clauses (SCCs) adopted by the European Commission.
Standard Contractual Clauses (SCCs) are pre-approved model contracts issued by the European Commission that provide a legally recognized mechanism for transferring personal data from the EU to a third country, such as the US, without requiring additional authorization. They are the most commonly accepted transfer mechanism because they impose contractual obligations on both the data exporter and importer to ensure adequate data protection, aligning with GDPR Article 46 requirements.
Key principle: Answer the scenario, not the keyword: identify the specific constraint before choosing the most familiar-sounding option.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✗
A data protection impact assessment (DPIA) approved by the local supervisory authority.
Why it's wrong here
A DPIA is a process to assess risk but is not a transfer mechanism; it may be required in addition to SCCs.
- ✓
Standard Contractual Clauses (SCCs) adopted by the European Commission.
Why this is correct
SCCs are a ready-to-use mechanism that provides contractual guarantees of adequate protection for cross-border data transfers.
Related concept
Read the scenario before looking for a memorised answer.
- ✗
Explicit consent from each data subject for the transfer.
Why it's wrong here
Consent can be withdrawn and is not considered a reliable long-term transfer mechanism under GDPR.
- ✗
Binding Corporate Rules (BCRs) for intra-group transfers.
Why it's wrong here
BCRs are valid for intra-group transfers but require lengthy approval from multiple authorities; SCCs are more common for simpler arrangements.
Common exam traps
Common exam trap: answer the scenario, not the keyword
The trap here is that candidates often confuse Binding Corporate Rules (BCRs) as the default intra-group mechanism, but SCCs are more commonly used because they are pre-approved, faster to implement, and do not require supervisory authority approval, making them the practical choice for most multinational transfers.
Detailed technical explanation
How to think about this question
SCCs operate by embedding specific data protection clauses (e.g., Module 1 for controller-to-controller, Module 2 for controller-to-processor) that mandate the data importer to adhere to GDPR-equivalent standards, including data breach notification, deletion timelines, and liability for sub-processors. Under the Schrems II ruling, SCCs must be supplemented with Transfer Impact Assessments (TIAs) and additional safeguards when transferring to countries with surveillance laws, such as the US under Section 702 FISA, to ensure essentially equivalent protection. A real-world scenario involves a US subsidiary using AWS for storage, where SCCs plus technical measures like encryption at rest (AES-256) and in transit (TLS 1.3) are required to mitigate risks from government access requests.
KKey Concepts to Remember
- Read the scenario before looking for a memorised answer.
- Find the constraint that changes the correct option.
- Eliminate answers that are true in general but not in this case.
TExam Day Tips
- Watch for words such as best, first, most likely and least administrative effort.
- Review why wrong options are wrong, not only why the correct option is correct.
Key takeaway
Answer the scenario, not the keyword: identify the specific constraint before choosing the most familiar-sounding option.
Real-world example
How this comes up in practice
A small business has 20 workstations on the 192.168.1.0/24 network and one public IP from its ISP. The router uses PAT (NAT overload) so all 20 devices share one public address using different source ports. NAT questions test whether you understand the four address terms and which direction each translation applies.
What to study next
Got this wrong? Here's your next step.
Identify which exam domain this question belongs to, review the core concept, then practise similar questions from the same domain.
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FAQ
Questions learners often ask
What does this CISA question test?
Protection of Information Assets — This question tests Protection of Information Assets — Read the scenario before looking for a memorised answer..
What is the correct answer to this question?
The correct answer is: Standard Contractual Clauses (SCCs) adopted by the European Commission. — Standard Contractual Clauses (SCCs) are pre-approved model contracts issued by the European Commission that provide a legally recognized mechanism for transferring personal data from the EU to a third country, such as the US, without requiring additional authorization. They are the most commonly accepted transfer mechanism because they impose contractual obligations on both the data exporter and importer to ensure adequate data protection, aligning with GDPR Article 46 requirements.
What should I do if I get this CISA question wrong?
Identify which exam domain this question belongs to, review the core concept, then practise similar questions from the same domain.
What is the key concept behind this question?
Read the scenario before looking for a memorised answer.
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Last reviewed: Jun 25, 2026
This CISA practice question is part of Courseiva's free ISACA certification practice question bank. Courseiva provides original exam-style practice questions with explanations, topic-based practice, mock exams, readiness tracking, and study analytics to help learners prepare for the CISA exam.
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