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CCSP Practice Question: A multinational corporation is migrating its…
A multinational corporation is migrating its customer data to a cloud provider that operates data centers in multiple jurisdictions. To comply with the General Data Protection Regulation (GDPR), the company must ensure that customer data remains within the European Economic Area (EEA) unless adequate safeguards are in place. The cloud provider offers data residency options but does not guarantee that data will never be accessed from outside the EEA. What is the BEST course of action for the company?
⚠ Common exam trap
ISC2 often tests the misconception that technical controls like encryption or pseudonymization alone can substitute for a legal transfer mechanism under GDPR, when in fact the regulation requires a recognized adequacy decision or appropriate safeguards (such as SCCs) regardless of the technical protections applied.
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
✓
Enter into a Data Processing Agreement (DPA) that includes Standard Contractual Clauses (SCCs) with the provider.
A Data Processing Agreement (DPA) with Standard Contractual Clauses (SCCs) is the correct mechanism under GDPR to lawfully transfer personal data outside the EEA when the cloud provider cannot guarantee that data will never be accessed from outside the EEA. SCCs are a set of contractual terms approved by the European Commission that impose obligations on both the data exporter and importer to ensure adequate data protection, even if the provider's data residency feature is not absolute. This approach directly addresses the GDPR requirement for adequate safeguards when data may be accessed from third countries.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✓
Enter into a Data Processing Agreement (DPA) that includes Standard Contractual Clauses (SCCs) with the provider.
Why this is correct
SCCs are a valid GDPR transfer mechanism.
- ✗
Accept the provider's data residency feature as sufficient compliance.
Why it's wrong here
Data residency alone does not ensure GDPR compliance for cross-border data access.
- ✗
Pseudonymize all customer data before uploading to the cloud.
Why it's wrong here
Pseudonymization does not exempt data from transfer restrictions.
- ✗
Encrypt all data and store the keys on-premises.
Why it's wrong here
Encryption does not eliminate the need for a legal transfer mechanism.
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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.