CISM Information Security Program Practice Question
A healthcare organization's information security program has a policy that requires all ePHI to be encrypted at rest. During a review, the CISO discovers that a legacy application storing ePHI does not support encryption. The application is critical for patient care and cannot be replaced immediately. Which of the following should the CISO do FIRST?
⚠ Common exam trap
The trap here is jumping to an exception or policy change without first assessing the risk, which could lead to inadequate risk management.
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
✓
Conduct a risk assessment to evaluate the potential impact and likelihood of a data breach.
The CISO should first conduct a risk assessment to quantify the risk posed by the unencrypted ePHI. This assessment will identify the likelihood and impact of a breach, and inform decisions about compensating controls, exceptions, or remediation timelines. Other actions, such as granting an exception or disconnecting the application, are premature without understanding the risk. The risk assessment ensures a balanced approach that considers patient care and compliance.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✗
Grant a policy exception for the legacy application and document the compensating controls.
Why it's wrong here
Granting an exception may be necessary eventually, but it should not be the first step. The CISO must first assess the risk and identify possible compensating controls. Jumping to an exception without a thorough risk analysis could be premature and may not satisfy compliance requirements. The first step is to understand the risk and explore options to mitigate it.
- ✗
Immediately disconnect the legacy application from the network to prevent a breach.
Why it's wrong here
Disconnecting the application would disrupt patient care, which is unacceptable given its criticality. The CISO must balance security with business continuity. A risk assessment should precede any drastic action. Disconnection might be a last resort if the risk is extreme, but it is not the first step and could cause more harm than good.
- ✗
Update the security policy to allow unencrypted ePHI for legacy systems.
Why it's wrong here
Changing the policy to accommodate a weakness is generally poor practice and could violate regulatory requirements such as HIPAA. Policies should reflect the organization's risk appetite and compliance obligations. The CISO should not weaken the policy without a thorough risk analysis and approval from governance. This option is a reactive measure that could increase risk exposure.
- ✓
Conduct a risk assessment to evaluate the potential impact and likelihood of a data breach.
Why this is correct
The first step is to conduct a risk assessment to understand the specific risks associated with the unencrypted ePHI. This assessment will inform whether an exception is warranted, what compensating controls are needed, and how to prioritize remediation. It is a fundamental risk management practice and aligns with the CISO's responsibility to manage risk to acceptable levels. Without it, any decision would be based on assumptions rather than data.
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JA
Written and reviewed by Johnson Ajibi, MSc IT Security
Senior Network & Security Engineer · founder of Courseiva
Last reviewed September 2026 · checked against the official ISACA exam blueprint
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.