ISC2 Governance, Risk and Compliance (CGRC) Practice Question
During a GDPR compliance audit, an EU supervisory authority asks how your organization will demonstrate the accountability principle defined in Article 5(2). Which of the following actions provides the most direct documentary evidence of compliance for the auditor?
Publish a comprehensive privacy notice on the public website describing all data uses.
Appoint a data protection officer even though the organization is not legally required to do so.
Maintain detailed, current records of processing activities for each business unit and make them available on request.
Encrypt all personal data at rest and in transit throughout the enterprise.
The accountability principle requires controllers to both comply with, and be able to demonstrate compliance with, the GDPR. Maintaining up-to-date Article 30 records of processing activities (ROPAs) creates a documented trail that must be made available to the supervisory authority on request, directly evidencing compliance. Encryption, privacy notices, and voluntarily appointing a DPO are valuable practices, but none are specifically intended to document and demonstrate overall compliance across all processing activities.
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What are Article 30 records of processing activities (ROPAs)?
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Why isn’t encryption sufficient to demonstrate GDPR compliance for the accountability principle?
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What is the role of a Data Protection Officer (DPO) under GDPR, and why is appointing one not sufficient for compliance?
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ISC2 Governance, Risk and Compliance (CGRC)
Security and Privacy Governance, Risk Management, and Compliance Program
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