This CCSP practice question tests your understanding of legal, risk and compliance. Compare every option against the stated constraints before choosing — the best answer satisfies all requirements, not just the most obvious one. After answering, compare your reasoning against the explanation and wrong-answer breakdown below. Once you have made your selection, read the full explanation to reinforce the concept and understand why each distractor is designed to mislead on exam day.
A multinational corporation uses a SaaS application for customer relationship management (CRM). The CRM application stores customer data including names, email addresses, and purchase history. The company has operations in the EU, California, and Japan. A new regulation in Japan requires that any transfer of personal data outside Japan must have the data subject's consent if the destination country does not have an adequacy decision. The company's cloud provider stores data in the United States. The company currently relies on the provider's data processing agreement that includes standard contractual clauses (SCCs). However, the Japanese regulator has stated that SCCs are not sufficient for transfers from Japan unless supplemented. You are tasked with ensuring compliance for Japanese data subjects. Which of the following is the most appropriate next step?
A. Obtain explicit consent from each Japanese data subject for data transfer to the US.
B. Move the data for Japanese subjects to a data center in Japan.
C. Continue using SCCs as they are recognized internationally.
D. Pseudonymize the data before transfer.
Which option best addresses the compliance requirement while considering the operational impact?
Clue words in this question
Noticing these words before you look at the options changes how you read each choice.
Clue: "best"
Why it matters: Signals that multiple options may be partially correct. Choose the option that most directly solves the exact problem described, not the one that sounds most complete.
Answer the question above first, then reveal the full breakdown to understand why each option is right or wrong.
Correct answer & explanation
✓
Obtain explicit consent from each Japanese data subject for data transfer to the US.
Option D is correct because the Japanese regulator has explicitly stated that SCCs alone are insufficient for transfers from Japan, and obtaining explicit consent from each data subject directly satisfies the requirement for a valid transfer mechanism under Japanese law. This approach ensures compliance without requiring infrastructure changes, though it may be operationally burdensome. The other options either fail to meet regulatory requirements or introduce unnecessary operational impact.
Key principle: Answer the scenario, not the keyword: identify the specific constraint before choosing the most familiar-sounding option.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
✗
Move the data for Japanese subjects to a data center in Japan.
Why it's wrong here
Moving data to Japan may be effective but is operationally complex and costly; consent is more immediate.
✗
Continue using SCCs as they are recognized internationally.
Why it's wrong here
The Japanese regulator has stated SCCs are not sufficient, so this would not ensure compliance.
✗
Pseudonymize the data before transfer.
Why it's wrong here
Pseudonymization reduces risk but does not eliminate the need for a transfer mechanism under Japanese law.
✓
Obtain explicit consent from each Japanese data subject for data transfer to the US.
Why this is correct
Correct. Explicit consent is a valid legal basis under Japanese law when other mechanisms are insufficient.
Clue confirmation
The clue word "best" in the question point toward this answer.
Related concept
Read the scenario before looking for a memorised answer.
Common exam traps
Common exam trap: answer the scenario, not the keyword
ISC2 often tests the misconception that pseudonymization or data localization alone can bypass cross-border transfer restrictions, when in fact explicit consent or an approved mechanism is required under the specific regulation.
Detailed technical explanation
How to think about this question
Under Japan's Act on the Protection of Personal Information (APPI), transfers to countries without an adequacy decision require either explicit consent or a recognized transfer mechanism. SCCs are a standard mechanism under GDPR but are not automatically accepted under APPI unless supplemented by additional safeguards, such as binding corporate rules or specific contractual provisions. Pseudonymization reduces risk but does not change the legal classification of the data as personal data under APPI, so transfer restrictions still apply.
KKey Concepts to Remember
Read the scenario before looking for a memorised answer.
Find the constraint that changes the correct option.
Eliminate answers that are true in general but not in this case.
TExam Day Tips
→Watch for words such as best, first, most likely and least administrative effort.
→Review why wrong options are wrong, not only why the correct option is correct.
Key takeaway
Answer the scenario, not the keyword: identify the specific constraint before choosing the most familiar-sounding option.
Real-world example
How this comes up in practice
A security analyst at a medium-sized enterprise encounters this scenario during an investigation or architecture review. The correct answer reflects best practice for the specific threat or control described. Answer the scenario, not the keyword: identify the specific constraint before choosing the most familiar-sounding option. Security exam questions test whether you can match controls to threats in context — not just recall definitions.
What to study next
Got this wrong? Here's your next step.
Identify which exam domain this question belongs to, review the core concept, then practise similar questions from the same domain.
Legal, Risk and Compliance — This question tests Legal, Risk and Compliance — Read the scenario before looking for a memorised answer..
What is the correct answer to this question?
The correct answer is: Obtain explicit consent from each Japanese data subject for data transfer to the US. — Option D is correct because the Japanese regulator has explicitly stated that SCCs alone are insufficient for transfers from Japan, and obtaining explicit consent from each data subject directly satisfies the requirement for a valid transfer mechanism under Japanese law. This approach ensures compliance without requiring infrastructure changes, though it may be operationally burdensome. The other options either fail to meet regulatory requirements or introduce unnecessary operational impact.
What should I do if I get this CCSP question wrong?
Identify which exam domain this question belongs to, review the core concept, then practise similar questions from the same domain.
Are there clue words in this question I should notice?
Yes — watch for: "best". Signals that multiple options may be partially correct. Choose the option that most directly solves the exact problem described, not the one that sounds most complete.
What is the key concept behind this question?
Read the scenario before looking for a memorised answer.
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Question Discussion
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