ISC2 Certified Cloud Security Professional (CCSP) Practice Question

A U.S.-based healthcare organization uses a cloud-hosted electronic health-record (EHR) service that stores patient data in the provider's primary data center located in Germany. The provider has not (yet) self-certified under the EU-U.S. Data Privacy Framework. To improve performance for American clinicians, the organization asks the provider to keep a near-real-time replica of the EHR database in the provider's U.S. region. Which single action best satisfies the GDPR's legal requirement for lawfully transferring this sensitive personal data from the EU to the United States?

  • Encrypt the database during replication using TLS 1.2 and invoke the GDPR's security exception for international transfers.

  • Rely on the cloud provider's lapsed EU-U.S. Safe Harbor certification as evidence of adequate protection.

  • Seek a one-time blanket consent from all patients authorizing future transfers of their data outside the European Economic Area.

  • Execute the European Commission's Standard Contractual Clauses (SCCs) between the German data exporter and the U.S. data importer before any replication occurs.

ISC2 Certified Cloud Security Professional (CCSP)
Legal, Risk and Compliance
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