ISC2 Certified Cloud Security Professional (CCSP) Practice Question
A U.S. SaaS vendor is preparing to migrate several data sets to a public cloud. The security team is separating information that can be protected solely by contract from information that must follow statutory or regulatory privacy rules. The following data sets are under review:
Hashed user passwords
Employee salary figures
Marketing contact list containing business e-mail addresses
Patient diagnosis codes captured by the vendor's tele-medicine module Which data set must be classified as regulated private data and therefore handled under specific legal requirements rather than just contractual obligations?
Hashed user passwords
Patient diagnosis codes from the tele-medicine module
Employee salary figures
Marketing contact list with business e-mail addresses
Patient diagnosis codes constitute protected health information (PHI). In the United States, PHI is regulated by the Health Insurance Portability and Accountability Act (HIPAA). Because HIPAA imposes legally mandated safeguards, breach notification, and use-and-disclosure rules, the data cannot be protected only through a contract with the cloud provider.
The other data sets are sensitive but are not subject to a dedicated federal privacy statute. They can be protected contractually through non-disclosure terms, information-security clauses, or industry best-practice frameworks, but they do not trigger HIPAA's regulated-data requirements.
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What is PHI (Protected Health Information) under HIPAA?
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How does HIPAA regulate the handling of PHI in the cloud?
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Why are hashed user passwords or employee salary figures not protected under HIPAA?
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ISC2 Certified Cloud Security Professional (CCSP)
Legal, Risk and Compliance
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