ISC2 Governance, Risk and Compliance (CGRC) Practice Question

During control selection for a new moderate-impact federal system that will store and transmit health-related PII, the ISSO finds that the standard moderate baseline does not fully address statutory privacy requirements. According to NIST guidance, what is the most appropriate way to introduce additional privacy-focused control enhancements?

  • Re-categorize the system as high impact and implement the full high baseline.

  • Replace access control family requirements with compensating controls documented only in the POA&M.

  • Rely exclusively on privacy controls inherited from the cloud service provider without changing the baseline.

  • Apply the NIST SP 800-53 privacy overlay to augment the moderate baseline with targeted privacy controls.

ISC2 Governance, Risk and Compliance (CGRC)
Selection and Approval of Framework, Security, and Privacy Controls
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