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CISM Practice Question: A multinational corporation must comply with both…
A multinational corporation must comply with both GDPR and CCPA. Which governance approach is most effective?
⚠ Common exam trap
Many candidates choose Option C (separate programs) thinking it ensures full compliance, but CISM emphasizes governance efficiency and risk management, where a unified framework with regional adjustments is the most effective approach to avoid duplication and control conflicts.
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
✓
Develop a unified data protection framework with regional adjustments
A unified data protection framework with regional adjustments allows the organization to maintain consistent governance principles while accommodating specific legal requirements of GDPR (e.g., data subject rights, 72-hour breach notification) and CCPA (e.g., opt-out rights, broader definition of personal information). This approach aligns with the CISM domain of Information Security Governance by enabling scalable, risk-based compliance without duplicating efforts or creating conflicts between policies.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✗
Create a single rigid unified policy applicable everywhere
Why it's wrong here
A single rigid policy cannot accommodate divergent requirements, such as GDPR's lawful-basis and transfer rules versus CCPA's opt-out sale provisions, so it breaches one regime. It is tempting because uniformity simplifies administration, and would be correct where jurisdictions impose equivalent, non-conflicting obligations.
- ✓
Develop a unified data protection framework with regional adjustments
Why this is correct
GDPR and CCPA share core principles but diverge on lawful basis, breach timelines and consumer rights. A single framework with regional overlays avoids duplicated controls while satisfying each jurisdiction's specific mandates, which is what the stem's dual-compliance constraint requires.
- ✗
Implement separate compliance programs for each regulation
Why it's wrong here
Separate programmes duplicate controls and create conflicting records for overlapping data subjects, rather than reconciling shared requirements such as lawful basis and access rights. It is tempting because the regulations differ in scope and penalties, and would be correct where obligations genuinely conflict and cannot be harmonised.
- ✗
Outsource compliance to a third-party service provider
Why it's wrong here
Outsourcing transfers processing to a provider, yet the corporation retains GDPR controller accountability and CCPA obligations, so it cannot delegate compliance itself. It is tempting because vendors supply specialist expertise, and would be correct for discrete operational tasks under retained governance, not for the governance approach itself.
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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.