CCSP Legal, Risk, and Compliance Practice Question
A US-based cloud customer stores EU personal data in a provider's Singapore region and uses the provider's support team located in India. The customer relies on the EU-US Data Privacy Framework (DPF) for its own US transfers. Which action is required to legitimize the support team's access to that EU data?
⚠ Common exam trap
The trap here is treating data residency or a provider's DPF certification as covering all global support access, when remote access from a non-certified third country is itself a regulated 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
✓
Verify the provider's DPF certification covers the Indian support entity and the Singapore processing, or put an Article 46 transfer tool in place for the India access.
A transfer occurs whenever personal data is made accessible to an entity in a third country, including remote support access. DPF certification only covers the certified entity and the data categories it lists, so the customer must confirm the Indian support team is covered or execute a valid Article 46 mechanism such as SCCs. Storage location alone does not resolve the transfer question.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✓
Verify the provider's DPF certification covers the Indian support entity and the Singapore processing, or put an Article 46 transfer tool in place for the India access.
Why this is correct
DPF certification is entity- and scope-specific: it only covers the certified US entity and the data categories and purposes listed. Remote access by a support team in India is itself a transfer to a third country, so the customer must confirm the certification's coverage or rely on an Article 46 mechanism such as SCCs for that access. Coverage cannot be assumed.
- ✗
Obtain a derogation under Article 49 for occasional support access, since break-fix support is by definition non-repetitive.
Why it's wrong here
Article 49 derogations are for occasional and non-repetitive transfers; routine support access under a managed service contract is neither. The EDPB has stated that recurring remote access cannot rely on derogations. Using Article 49 here would create a systematic compliance gap rather than a valid transfer basis.
- ✗
Rely on the provider's Singapore data residency commitment because data stored in-region never leaves the jurisdiction.
Why it's wrong here
Data residency describes where data is stored, not who can access it. The India-based support team's remote access constitutes a transfer of personal data to a third country under EDPB Guidelines 05/2021, regardless of storage location. Residency commitments do not legitimize that access, so this action leaves an unlawful transfer in place.
- ✗
Adopt binding corporate rules covering the customer's own corporate group, which automatically extends to provider personnel.
Why it's wrong here
BCRs bind the corporate group that obtained approval; they do not extend to a third-party provider's staff in another country. The provider would need its own approved BCRs or another transfer mechanism. Because the customer's BCRs cannot cover the provider's Indian support entity, this approach does not legitimize the access.
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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.