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?
Tokenize all stored Social Security numbers before taking any other action.
Notify affected employees and regulators within 72 hours because every undocumented transfer is automatically a breach.
Suspend the unapproved transfer at once and initiate a formal investigation and risk assessment.
Update the data-flow diagram to document the new cross-border path, then schedule a compliance review.
The priority is to stop the unauthorized cross-border transfer immediately and launch a formal investigation and risk assessment. Halting the flow contains any further potential exposure and allows the organization to determine legality, security impact, and necessary notifications. Once the incident is contained and assessed, the data-flow diagram, GDPR Article 30 records, and other documentation can be updated, and additional controls (such as tokenization) or remediation (such as purging data) can be planned. Not every undocumented international transfer is automatically a notifiable breach, so notifications should follow the investigation if required.
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What is GDPR Article 30 and why is it important?
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What is tokenization, and how does it help secure sensitive data?
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What constitutes a 'notifiable breach' according to GDPR?
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ISC2 Governance, Risk and Compliance (CGRC)
Security and Privacy Governance, Risk Management, and Compliance Program
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