ISC2 Certified Cloud Security Professional (CCSP) Practice Question
A U.S. hospital is migrating its electronic health record (EHR) system to a public IaaS provider. Protected health information (PHI) will be stored and processed in the cloud, but the provider will not create or modify any records. According to HIPAA requirements, which contractual document must the hospital have in place with the cloud service provider before moving any PHI to the environment?
A Data Processing Addendum drafted to meet GDPR Article 28 requirements
A SOC 2 Type II report demonstrating the provider's control effectiveness over one year
A PCI Report on Compliance confirming adherence to payment card standards
A Business Associate Agreement that defines permitted uses and required safeguards for PHI
Under the HIPAA Privacy and Security Rules, any third party that creates, receives, maintains, or transmits PHI on behalf of a covered entity is a business associate. HIPAA (45 CFR §164.308(b) and §164.502(e)) requires the covered entity to execute a Business Associate Agreement (BAA) with each business associate-including cloud service providers-before PHI is disclosed. A PCI Report on Compliance and a SOC 2 Type II report are useful for other assurance purposes but are not mandated by HIPAA. A GDPR-focused Data Processing Addendum addresses EU personal data and does not satisfy HIPAA's specific contractual obligation. Therefore, the BAA is the mandatory document.
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ISC2 Certified Cloud Security Professional (CCSP)
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