ISC2 Governance, Risk and Compliance (CGRC) Practice Question
You are developing a control implementation strategy for a U.S. health provider launching a telehealth app that will collect EU residents' personal health data. To align with applicable national and international requirements, which additional step should you include before deployment?
Map system audit logs to the MITRE ATT&CK framework for future threat hunting.
Update all service-level agreements to reference the FedRAMP Moderate security baseline only.
Conduct a Data Protection Impact Assessment to address GDPR obligations before processing EU personal data.
Rely on the HIPAA Privacy Rule's safe harbor to process patient data globally without further analysis.
Because the app will process sensitive health information of data subjects located in the European Union, the organization becomes a controller under the GDPR. Article 35 of the GDPR requires a Data Protection Impact Assessment (DPIA) for processing that is likely to result in high risk to individuals' rights and freedoms-such as large-scale remote health services. Performing and documenting the DPIA demonstrates that the implementation strategy accounts for international legal obligations. Mapping logs to MITRE ATT&CK supports threat modeling, not legal compliance. Limiting contracts to FedRAMP Moderate only addresses U.S. federal cloud requirements, not EU privacy law. Relying solely on HIPAA safe harbor does not satisfy GDPR obligations, so it would leave the organization non-compliant.
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What is the purpose of a Data Protection Impact Assessment (DPIA)?
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ISC2 Governance, Risk and Compliance (CGRC)
Implementation of Security and Privacy Controls
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