- A
Enable client-side encryption using a custom key management system (KMS) on the customer's premises.
Correct. Client-side encryption with customer-controlled keys ensures compliance and maintains security.
- B
Disable encryption and rely on access controls and auditing only.
Why wrong: Disabling encryption would violate HIPAA's requirements for protecting ePHI.
- C
Use the provider's default encryption and rely on their BAA that states they will protect the keys.
Why wrong: BAA does not provide exclusive customer control over keys, which may not meet HIPAA requirements.
- D
Implement a third-party key management solution that stores keys in the cloud but is controlled by the customer.
Why wrong: Storing keys in the cloud still exposes them to the provider's infrastructure, potentially violating the control requirement.
CCSP Legal, Risk and Compliance Practice Question
This CCSP practice question tests your understanding of legal, risk and compliance. Read the scenario carefully and evaluate each option against the stated constraints before committing to an answer. 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.
Your organization, a healthcare provider subject to HIPAA, has migrated electronic protected health information (ePHI) to a public cloud IaaS provider. The cloud provider offers default encryption at rest using their managed key service. During a recent audit, it was discovered that the encryption keys are generated and stored by the cloud provider without any customer involvement. The auditor states that this arrangement may violate HIPAA requirements because the covered entity does not have exclusive control over the keys. You need to ensure compliance while maintaining cost efficiency. After discussing with the cloud provider, they suggest the following options: A. Enable client-side encryption using a custom key management system (KMS) on the customer's premises. B. Use the provider's default encryption and rely on their BAA that states they will protect the keys. C. Implement a third-party key management solution that stores keys in the cloud but is controlled by the customer. D. Disable encryption and rely on access controls and auditing only.
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 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
Enable client-side encryption using a custom key management system (KMS) on the customer's premises.
Option A is correct because client-side encryption with a customer-controlled KMS ensures the covered entity retains exclusive control over the encryption keys, meeting HIPAA's requirement that the covered entity must be able to prevent the cloud provider from accessing ePHI. By encrypting data before it leaves the customer premises, the cloud provider never has access to the plaintext keys, and the customer maintains full lifecycle management, including key rotation and revocation. This approach is cost-efficient as it avoids complex third-party integrations and leverages existing on-premises infrastructure.
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.
- ✓
Enable client-side encryption using a custom key management system (KMS) on the customer's premises.
Why this is correct
Correct. Client-side encryption with customer-controlled keys ensures compliance and maintains security.
Clue confirmation
The clue word "best" in the question point toward this answer.
Related concept
Read the scenario before looking for a memorised answer.
- ✗
Disable encryption and rely on access controls and auditing only.
Why it's wrong here
Disabling encryption would violate HIPAA's requirements for protecting ePHI.
- ✗
Use the provider's default encryption and rely on their BAA that states they will protect the keys.
Why it's wrong here
BAA does not provide exclusive customer control over keys, which may not meet HIPAA requirements.
- ✗
Implement a third-party key management solution that stores keys in the cloud but is controlled by the customer.
Why it's wrong here
Storing keys in the cloud still exposes them to the provider's infrastructure, potentially violating the control requirement.
Common exam traps
Common exam trap: answer the scenario, not the keyword
ISC2 often tests the misconception that a Business Associate Agreement (BAA) alone is sufficient to satisfy HIPAA encryption requirements, when in fact the covered entity must maintain exclusive control over encryption keys to prevent unauthorized access by the cloud provider.
Detailed technical explanation
How to think about this question
Client-side encryption typically uses envelope encryption where a data encryption key (DEK) is encrypted by a key encryption key (KEK) managed by the customer's KMS, and only the encrypted DEK is sent to the cloud. This ensures the cloud provider never has access to the plaintext KEK, aligning with HIPAA's requirement for the covered entity to be the sole key custodian. In practice, this can be implemented using AWS KMS with a custom key store backed by AWS CloudHSM, or using Azure Key Vault with managed HSM, but the key must be generated and stored outside the provider's control to satisfy audit requirements.
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 developer is choosing between AES-256 (symmetric) and RSA-2048 (asymmetric) for encrypting a large file that will be sent to a partner. Symmetric encryption is fast but requires key exchange; asymmetric is slower but solves the key distribution problem. A hybrid approach — encrypt the file with AES, encrypt the AES key with RSA — is standard. Questions like this test whether you understand when each approach applies.
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.
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Legal, Risk and Compliance — study guide chapter
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FAQ
Questions learners often ask
What does this CCSP question test?
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: Enable client-side encryption using a custom key management system (KMS) on the customer's premises. — Option A is correct because client-side encryption with a customer-controlled KMS ensures the covered entity retains exclusive control over the encryption keys, meeting HIPAA's requirement that the covered entity must be able to prevent the cloud provider from accessing ePHI. By encrypting data before it leaves the customer premises, the cloud provider never has access to the plaintext keys, and the customer maintains full lifecycle management, including key rotation and revocation. This approach is cost-efficient as it avoids complex third-party integrations and leverages existing on-premises infrastructure.
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.
About these practice questions
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Last reviewed: Jun 30, 2026
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.
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