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CCSP Practice Question: A US-based company uses a cloud provider with…
A US-based company uses a cloud provider with data centers in the US and Europe. To transfer personal data of EU citizens to the US, which mechanism is most appropriate under GDPR?
⚠ Common exam trap
ISC2 often tests the misconception that an adequacy decision is the default or most straightforward option for US transfers, but the trap is that the US currently lacks an adequacy decision, making SCCs the primary lawful mechanism for such cross-border data flows.
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
✓
Standard Contractual Clauses (SCCs)
Standard Contractual Clauses (SCCs) are the most appropriate mechanism because they provide a legally recognized data transfer tool under GDPR Article 46 for transferring personal data from the EU to a third country (the US) without an adequacy decision. SCCs are pre-approved contractual terms that both the data exporter (EU-based) and data importer (US-based) must sign, ensuring adequate safeguards for the data subjects' rights. This mechanism is specifically designed for scenarios where the cloud provider's data centers span jurisdictions without a current adequacy finding, as is the case with the US post-Schrems II.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✗
Explicit consent
Why it's wrong here
Consent can be used but is not the most practical for routine data transfers.
- ✓
Standard Contractual Clauses (SCCs)
Why this is correct
Correct. SCCs are a recognized transfer mechanism for data transfers to third countries.
- ✗
Binding Corporate Rules (BCRs)
Why it's wrong here
BCRs are for transfers within a corporate group, not for transfers to a third-party cloud provider.
- ✗
Adequacy decision
Why it's wrong here
The US does not have an adequacy decision under GDPR.
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JA
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.