CISM Information Security Program Practice Question
A financial institution's security program must comply with PCI DSS, GDPR, and SOX. Which approach is MOST efficient to manage overlapping compliance requirements?
⚠ Common exam trap
Test-takers frequently think focusing on the strictest regulation (Option B) is efficient, but they overlook that each regulation has unique non-overlapping requirements (e.g., GDPR's breach notification timeline vs. PCI DSS's quarterly scans) that must be addressed separately.
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 a single control set mapped to all applicable regulations
Implementing a single control set mapped to all applicable regulations (PCI DSS, GDPR, SOX) leverages common controls to satisfy overlapping requirements efficiently. This approach reduces duplication of effort, simplifies audit preparation, and ensures consistent security posture across the organization. For example, access control requirements under PCI DSS 7.1, GDPR Article 32, and SOX Section 404 can be addressed by a unified identity and access management (IAM) policy with role-based access controls (RBAC) and logging.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✗
Develop three separate control sets for each regulation
Why it's wrong here
Maintaining three separate control sets triples documentation, testing and evidence effort for controls that address the same underlying requirement, defeating efficiency. It is tempting because separate control sets give clean, unambiguous traceability to each regulation, which suits highly regulated environments where auditors demand framework-specific mapping and no shared-control ambiguity is acceptable.
- ✗
Focus only on the requirements of the strictest regulation
Why it's wrong here
Aligning only to the strictest regulation leaves controls satisfying PCI DSS, GDPR or SOX unmet where that framework's scope differs, creating compliance gaps. It is tempting because a strictest-framework baseline genuinely reduces duplication when the frameworks' requirements are truly nested, but PCI DSS, GDPR and SOX impose distinct obligations that do not fully overlap.
- ✓
Implement a single control set mapped to all applicable regulations
Why this is correct
A single unified control set mapped to PCI DSS, GDPR and SOX lets one implementation satisfy overlapping obligations, avoiding duplicated effort and evidence collection. Mapping each framework separately multiplies audit work and creates conflicting control definitions.
- ✗
Engage external auditors to manage compliance for each regulation
Why it's wrong here
Outsourcing each regulation to separate external auditors multiplies cost and coordination without consolidating overlapping controls, so effort scales with the number of frameworks rather than being reduced. It is tempting because external auditors provide independent assurance and specialist regulatory expertise, which suits one-off attestation or gap assessments rather than ongoing multi-framework management.
Quick reference
Access Control Model Comparison
| Model | Acronym | Who Controls Access? | Best For |
|---|---|---|---|
| Discretionary Access Control | DAC | Resource owner | Small teams, file shares |
| Mandatory Access Control | MAC | System / security labels | Classified govt / military |
| Role-Based Access Control | RBAC | Administrator (via roles) | Enterprise environments |
| Attribute-Based Access Control | ABAC | Policy engine (user + resource attributes) | Fine-grained, dynamic policies |
| Rule-Based Access Control | RuBAC | System rules / ACLs | Firewall rules, network ACLs |
Go deeper
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JA
Written by Johnson Ajibi, MSc IT Security
Senior Network & Security Engineer · founder of Courseiva
This CISM 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 CISM exam.