CCSP Legal, Risk, and Compliance Practice Question
A covered entity under HIPAA is planning to migrate electronic protected health information (ePHI) to a public cloud environment. Which of the following is a mandatory requirement before using the cloud service?
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
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Obtain a signed Business Associate Agreement from the cloud provider
HIPAA requires covered entities to obtain satisfactory assurances that PHI will be protected, typically through a Business Associate Agreement (BAA) with the cloud provider.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
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Encrypt all ePHI with keys managed solely by the covered entity
Why it's wrong here
HIPAA requires a signed business associate agreement and appropriate safeguards; it mandates neither customer-managed keys nor sole key custody, and provider-managed encryption satisfies the Security Rule. It is tempting because customer-controlled keys strengthen confidentiality, and would be correct where the risk assessment identifies key custody as a required control.
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Conduct a physical on-site audit of the cloud provider's data centers
Why it's wrong here
HIPAA imposes no obligation to physically inspect a cloud provider's data centres; assurance is obtained through the business associate agreement and the provider's independent audits. It is tempting because on-site inspection suits self-hosted infrastructure, but public cloud tenants have no such access rights.
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Obtain a signed Business Associate Agreement from the cloud provider
Why this is correct
HIPAA requires a Business Associate Agreement before any covered entity shares ePHI with a cloud provider, since the provider qualifies as a business associate. The signed BAA contractually binds the provider to safeguard ePHI and satisfies the mandatory prerequisite for cloud migration.
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Ensure the cloud provider is certified under the Privacy Shield framework
Why it's wrong here
Privacy Shield was invalidated by the Schrems II ruling in 2020 and never applied to HIPAA-covered entities anyway; it governed EU-US personal data transfers. It is tempting because it sounds like a data-protection certification, and it would have been relevant for EU personal data transfers before invalidation.
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Written by Johnson Ajibi, MSc IT Security
Senior Network & Security Engineer · founder of Courseiva
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.