CISSP Asset Security Practice Question
A company collects PII from European customers for order processing. Under GDPR, they engage a third-party logistics provider to handle shipping. Which role does the logistics provider typically assume in this scenario?
⚠ Common exam trap
CISSP often tests the confusion between controller and processor, and the invented-sounding 'data custodian' role, which is not a GDPR legal designation.
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
✓
Data processor
Under GDPR, the logistics provider processes personal data on behalf of the company and therefore assumes the role of data processor. The company that determines the purposes and means of processing is the data controller, and the processor acts only on the controller's documented instructions. This controller-processor relationship must be governed by a written data processing agreement.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✗
Data controller
Why it's wrong here
The controller determines the purposes and means of processing; the logistics provider merely processes PII on the company's instructions, making it a processor. It is tempting because the company does control the data, but that role belongs to the company, not its shipping vendor.
- ✗
Data custodian
Why it's wrong here
Data custodian is an internal operational role for day-to-day safeguarding of data, not a GDPR legal designation. It is tempting because custodians do handle data storage and protection, but GDPR assigns the logistics provider the processor role, defined by processing on the controller's behalf.
- ✓
Data processor
Why this is correct
The logistics provider processes PII solely on the controller's documented instructions for shipping, satisfying GDPR's Article 28 processor definition. It determines neither purposes nor means of processing, unlike a controller or joint controller. This distinction hinges on decision-making authority over processing, not data volume or technical access.
- ✗
Data subject
Why it's wrong here
A data subject is the identifiable natural person whose PII is processed, so a corporate logistics provider cannot occupy that role. It is tempting because the term appears throughout GDPR text, but it applies to the European customers, not to a third-party shipping organisation.
Go deeper
Related to this question
Learn chapter
Asset Security: Privacy and Data Retention
Key term
Data controller
An entity that determines the purposes and means of processing personal data.
Key term
GDPR
The General Data Protection Regulation (GDPR) is a European Union law that sets strict rules for how organizations collect, store, process, and protect the personal data of individuals within the EU.
About these practice questions
One of 816 original CISSP practice questions on Courseiva, each with a full explanation and wrong-answer analysis — not exam dumps or protected exam content. Learn why practice questions differ from exam dumps →
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 CISSP 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 CISSP exam.