ISC2 Governance, Risk and Compliance (CGRC) Practice Question

During a periodic review of an HR payroll application, you learn that employee Social Security numbers are being sent to an overseas payroll processor-a data transfer that was never documented or approved. Which action should you take first?

  • Notify affected employees and regulators within 72 hours because every undocumented transfer is automatically a breach.

  • Update the data-flow diagram to document the new cross-border path, then schedule a compliance review.

  • Suspend the unapproved transfer at once and initiate a formal investigation and risk assessment.

  • Tokenize all stored Social Security numbers before taking any other action.

ISC2 Governance, Risk and Compliance (CGRC)
Security and Privacy Governance, Risk Management, and Compliance Program
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