CCSP Legal, Risk, and Compliance Practice Question
A cloud customer is subject to the EU GDPR and stores personal data with a provider that replicates it across data centers in several countries. The customer's legal team must confirm that appropriate safeguards exist for each international transfer. Which TWO elements are required for a valid transfer under GDPR Chapter V? (Choose two.)
⚠ Common exam trap
The trap here is treating a security or privacy certification as a substitute for a Chapter V transfer mechanism, when certifications support due diligence but do not authorize the transfer.
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
✓
A transfer impact assessment documenting the destination country's laws and any supplementary measures
A valid Chapter V transfer needs a legal mechanism, such as an adequacy decision or Standard Contractual Clauses, plus a documented transfer impact assessment that evaluates destination-country laws and any supplementary measures. Certifications and registrations may support due diligence but are not transfer mechanisms. When data is replicated across several countries, both elements must cover every jurisdiction where personal data resides or is accessible.
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 transfer impact assessment documenting the destination country's laws and any supplementary measures
Why this is correct
Following the Schrems II judgment, controllers must assess whether the destination country's surveillance and access laws undermine the chosen safeguard, and if so, adopt supplementary measures such as encryption or pseudonymization. This assessment must be documented and reviewed, especially when data is replicated to several countries with differing legal regimes.
- ✓
A lawful transfer mechanism such as an adequacy decision or Standard Contractual Clauses
Why this is correct
Chapter V requires a legal basis for each third-country transfer, either an adequacy decision under Article 45 or an appropriate safeguard under Article 46 such as SCCs. Because the provider replicates data across multiple jurisdictions, the customer must confirm that a valid mechanism covers every destination where personal data is stored or accessible, not just the primary region.
- ✗
A SOC 2 Type II report covering the provider's security controls in each region
Why it's wrong here
A SOC 2 report attests to security, availability, or confidentiality controls but is not a GDPR transfer mechanism. It can support due diligence and demonstrate that encryption or access controls exist, yet it does not provide the legal basis required by Chapter V. A provider could hold a clean SOC 2 report and still lack a valid transfer safeguard.
- ✗
Registration of the cloud provider as a data controller with the customer's supervisory authority
Why it's wrong here
Registering a provider as a controller does not create a transfer safeguard, and the provider typically acts as a processor in this arrangement. Controller registration obligations apply to the controller's own processing activities and do not substitute for an Article 45 or Article 46 mechanism. This option mischaracterizes both the provider's role and the transfer requirements.
- ✗
An ISO/IEC 27701 certification held by the cloud provider
Why it's wrong here
ISO/IEC 27701 extends ISO/IEC 27001 to privacy information management and can evidence a mature privacy program, but it is not a recognized Chapter V transfer tool. Certification does not bind the provider to specific data subject rights or government-access protections the way SCCs do. It may support the transfer impact assessment but cannot replace the required legal mechanism.
About these practice questions
This CCSP question is part of Courseiva's 934-question bank — original exam-style content with full explanations and wrong-answer analysis, never real exam questions or exam dumps. Learn why practice questions differ from exam dumps →
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 ISC2 exam blueprint
This CCSP practice question is part of Courseiva's free ISC2 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 CCSP exam.