CCSP Legal, Risk, and Compliance Practice Question
A healthcare organization stores protected health information (PHI) in a cloud environment. Under HIPAA, what must the organization obtain from the cloud provider before processing PHI?
⚠ Common exam trap
The trap is confusing GDPR's DPA with HIPAA's BAA; candidates may think any data processing agreement suffices, but HIPAA specifically requires a BAA for PHI.
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 Business Associate Agreement (BAA)
Under HIPAA, a covered entity must obtain a Business Associate Agreement (BAA) from any cloud provider that creates, receives, maintains, or transmits protected health information (PHI) on its behalf. The BAA establishes the permitted uses and disclosures of PHI and requires the business associate to implement safeguards.
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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A Data Processing Agreement (DPA) under GDPR
Why it's wrong here
A GDPR Data Processing Agreement governs EU personal-data processing, not US PHI, so it does not satisfy HIPAA. It is tempting because it is the correct choice when a controller engages a processor for EU personal data under GDPR Article 28.
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A Business Associate Agreement (BAA)
Why this is correct
A BAA is mandatory under HIPAA before a covered entity may disclose PHI to a cloud provider, which acts as a business associate. It contractually binds the provider to safeguard PHI, satisfying the stem's requirement to obtain an agreement prior to processing.
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A Service Organization Control (SOC) 2 report
Why it's wrong here
A SOC 2 report is an attestation of a provider's controls, not an authorisation instrument; HIPAA requires a signed Business Associate Agreement before PHI is processed. Requesting SOC 2 is tempting because it evidences security posture during vendor due diligence, but it neither permits nor governs PHI handling.
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An ISO 27001 certification
Why it's wrong here
ISO 27001 certifies an information security management system; it creates no HIPAA obligation between the parties. It is tempting because it is the correct choice when you need assurance of a provider's security controls, not the Business Associate Agreement HIPAA requires.
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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 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.