The scenario describes a cloud service provider (CSP) that has been notified of a data breach impacting personal data of individuals whose data is processed on its platform. According to ISO 27018:2019, specifically clause 8.2, the CSP has obligations regarding the notification of personal data breaches. This clause mandates that the CSP shall, without undue delay, notify the relevant supervisory authority and, where applicable, the data subjects, about a personal data breach. The notification should include specific details about the nature of the breach, the categories and approximate number of data subjects concerned, the likely consequences of the breach, and the measures taken or proposed to be taken by the CSP to address the breach. The prompt highlights that the CSP is considering a notification strategy that focuses solely on informing the data controller (the customer using the cloud service) and not the data subjects directly, citing the complexity of identifying and contacting affected individuals. This approach deviates from the standard requirement of notifying data subjects when appropriate. Therefore, the most accurate assessment of the CSP’s proposed action, in relation to ISO 27018:2019, is that it is insufficient because it fails to address the potential obligation to notify data subjects directly, which is a core tenet of the standard when such breaches occur and impact their personal data. The standard emphasizes transparency and the rights of individuals whose data is compromised.

The core of ISO 27018:2019, particularly concerning the protection of Personally Identifiable Information (PII) in public cloud environments, revolves around the responsibilities and obligations of both the cloud service provider (CSP) and the cloud service customer (CSC). Clause 6.1.1 of the standard explicitly addresses the CSP’s responsibility to inform the CSC about the PII processed by the CSP on behalf of the CSC. This notification is crucial for enabling the CSC to fulfill its own data protection obligations, which are often dictated by various data privacy regulations like GDPR, CCPA, or PIPEDA, depending on the jurisdiction and the data subjects involved. The CSP must provide sufficient detail for the CSC to understand the scope and nature of the processing. This includes information about the types of PII being processed, the purposes of processing, and the locations where the PII is stored and processed. Without this transparency, the CSC cannot adequately assess risks, implement appropriate controls, or respond to data subject requests, thereby undermining the entire framework of PII protection in the cloud. Therefore, the CSP’s proactive and comprehensive disclosure is a foundational element for establishing a compliant and secure cloud data processing relationship.

No calculation is required for this question as it assesses conceptual understanding of data subject rights within the context of ISO 27018:2019. The standard, in conjunction with relevant data protection regulations like GDPR, mandates that cloud service providers (CSPs) facilitate the exercise of data subject rights. This includes the right to access, rectify, erase, and restrict the processing of personal data. When a CSP is acting as a data processor on behalf of a data controller (the customer), the CSP’s contractual obligations and technical capabilities must enable the controller to fulfill these requests. Specifically, the CSP must provide mechanisms or support that allow the controller to identify, locate, and act upon the personal data of the data subject. This involves having robust data management and retrieval systems, as well as clear procedures for handling such requests. The ability to demonstrate compliance with these rights is a core tenet of responsible PII processing in public cloud environments, ensuring that individuals can maintain control over their information even when it is hosted by a third party. The correct approach involves the CSP actively supporting the data controller’s ability to meet these obligations, rather than simply stating that the controller is responsible. This support is demonstrated through documented processes, technical capabilities, and contractual commitments that align with the principles of data protection by design and by default.

The core principle guiding the response of a Cloud Service Provider (CSP) to a Personal Identifiable Information (PII) breach, as stipulated by ISO 27018:2019, is to act in accordance with the contractual agreements with the customer and relevant legal obligations. This involves a multi-faceted approach that prioritizes transparency, containment, and remediation. Specifically, the CSP must notify the customer without undue delay, providing all pertinent details about the breach, including the nature of the PII affected, the potential impact, and the measures being taken. This aligns with the standard’s emphasis on the CSP’s responsibility to assist the customer in fulfilling their own data breach notification obligations under applicable data protection laws, such as the GDPR or CCPA. The CSP’s role is to facilitate the customer’s response, not to usurp it, unless explicitly agreed upon. Therefore, the most appropriate action is to provide comprehensive information and support to the customer to enable them to manage their legal and regulatory duties. This includes offering technical assistance for investigation and remediation, and ensuring that any actions taken by the CSP are coordinated with the customer’s overall incident response strategy. The standard emphasizes collaboration and clear communication channels to mitigate the impact of a breach on individuals whose PII has been compromised.

The core of ISO 27018:2019 revolves around the responsibilities of cloud service providers (CSPs) in protecting personally identifiable information (PII) processed on behalf of cloud service customers (CSCs). Clause 6.1.1, “Responsibilities for PII,” is pivotal. It mandates that the CSP shall inform the CSC about the CSP’s responsibilities concerning the protection of PII. This includes clearly delineating which aspects of PII protection fall under the CSP’s purview and which remain the CSC’s responsibility. This is often achieved through contractual agreements, service level agreements (SLAs), and documented policies. The standard emphasizes transparency and mutual understanding of roles to ensure comprehensive PII protection. The correct approach involves the CSP proactively communicating its security controls, data handling practices, and the scope of its compliance with ISO 27018 to the CSC. This communication should be ongoing and readily accessible, enabling the CSC to make informed decisions about using the CSP’s services and to fulfill its own data protection obligations, such as those under regulations like GDPR or CCPA. The explanation focuses on the CSP’s obligation to inform the CSC about its role in PII protection, a fundamental aspect of the standard’s framework for shared responsibility in cloud environments.

The core principle being tested here is the responsibility of the cloud service provider (CSP) in relation to the processing of personal data on behalf of a customer, specifically concerning data subject rights and notification obligations in the context of a data breach. ISO 27018:2019, clause 6.3.3, addresses the CSP’s role in assisting the customer (the data controller) with data subject requests. Clause 6.3.4 specifically mandates that the CSP shall inform the customer without undue delay of a personal data breach. The scenario describes a situation where a CSP detects a breach affecting customer data. The CSP’s obligation is to notify the customer promptly. The customer, as the data controller, then has the responsibility to assess the breach and, if necessary, notify the relevant supervisory authority and data subjects, as required by regulations like the GDPR. Therefore, the CSP’s immediate action should be to inform the customer. The other options represent actions that are either the customer’s primary responsibility (notifying authorities/subjects) or a secondary, less immediate action for the CSP (providing detailed forensic reports before initial notification). The prompt notification to the customer is the foundational step mandated by the standard to enable the customer to fulfill their own obligations.

The core of ISO 27018:2019 is to ensure that cloud service providers (CSPs) that process personally identifiable information (PII) on behalf of cloud service customers (CSCs) protect that PII from unauthorized disclosure or use. Clause 6.2.1 of the standard specifically addresses the CSP’s responsibility to inform the CSC about the processing of PII. This includes providing information about the types of PII processed, the purposes of processing, and any onward transfers of PII to third parties. The CSP must also inform the CSC about any legal obligations that might impact the processing of PII, such as data localization requirements or government access requests, which are often influenced by the jurisdiction where the data is stored or processed. The standard emphasizes transparency and the need for the CSP to act only on the documented instructions of the CSC, unless otherwise required by law. Therefore, understanding the CSP’s obligation to communicate potential legal impacts on PII processing is crucial for the CSC to maintain compliance with relevant data protection regulations, like the GDPR or CCPA, and to make informed decisions about cloud service usage. The correct approach involves the CSP proactively disclosing any known or anticipated legal constraints that could affect the PII processing activities agreed upon with the CSC.

The core of ISO 27018:2019 is to provide guidance on the protection of Personally Identifiable Information (PII) in public cloud environments. A key aspect of this standard is how it addresses the responsibilities of both the cloud service provider (CSP) and the cloud service customer (CSC) regarding PII. Specifically, the standard emphasizes that the CSP is responsible for the security of the cloud infrastructure and the services it provides, while the CSC is responsible for the PII that it processes and stores within that cloud environment. When a CSP acts as a data processor for a CSC, the standard outlines specific contractual and operational requirements to ensure PII protection. This includes clauses related to data breach notification, data deletion, and the handling of data subject requests. The standard also acknowledges the role of relevant data protection legislation, such as the GDPR, and how it interacts with the contractual agreements between CSPs and CSCs. Therefore, when a CSP processes PII on behalf of a CSC, the contractual framework must clearly delineate these responsibilities, ensuring that the CSP’s actions align with the CSC’s obligations under applicable laws and the principles of ISO 27018. The correct understanding lies in recognizing the shared responsibility model and the contractual mechanisms that enforce it, particularly concerning the CSP’s role as a processor.

The core of ISO 27018:2019 revolves around the responsibilities of cloud service providers (CSPs) in protecting personally identifiable information (PII) processed on their behalf by cloud service customers (CSCs). Clause 5.2.1 specifically addresses the CSP’s obligation to inform CSCs about the processing of PII. This includes providing information regarding the purposes of processing, the types of PII processed, and the locations where processing occurs. Furthermore, the standard emphasizes the CSP’s role in assisting CSCs with their compliance obligations, particularly concerning data subject rights. When a CSP receives a request from a data subject to exercise their rights (e.g., access, rectification, erasure), the CSP must provide reasonable assistance to the CSC to fulfill this request. This assistance involves providing the necessary technical and organizational measures to enable the CSC to respond effectively. The CSP cannot directly fulfill the data subject’s request without the CSC’s explicit instruction and authorization, as the CSC remains the data controller. Therefore, the CSP’s primary duty is to facilitate the CSC’s ability to meet these demands, which includes providing information and technical support. The concept of “reasonable assistance” is crucial here, implying that the CSP should offer practical and actionable support, not merely a statement of intent. This aligns with the shared responsibility model inherent in cloud computing, where the CSP manages the underlying infrastructure and security, while the CSC manages the data and its processing.

The scenario describes a cloud service provider (CSP) offering services to a data controller that processes personal data of EU citizens. The CSP is acting as a data processor. ISO 27018:2019, in conjunction with regulations like the GDPR, mandates specific responsibilities for CSPs when handling PII in the cloud. Clause 6.2.1 of ISO 27018:2019 addresses the “Obligations of the CSP as a data processor.” This clause emphasizes the CSP’s duty to process PII only according to the instructions of the data controller and to assist the controller in fulfilling their data protection obligations. This includes providing necessary information and support for data subject rights requests, breach notifications, and data protection impact assessments. The CSP’s commitment to providing a framework for data protection, as outlined in its privacy policy and service agreements, is crucial. However, the ultimate responsibility for compliance with data protection laws, such as the GDPR’s requirements for lawful processing, data minimization, and purpose limitation, rests with the data controller. The CSP’s role is to enable and support the controller’s compliance through its security and privacy controls and contractual commitments. Therefore, the CSP’s primary obligation is to act as a processor under the controller’s direction and to provide the necessary assurances and assistance to meet the controller’s legal duties.

The core of ISO 27018:2019 is to provide guidance on the protection of Personally Identifiable Information (PII) in public cloud environments. Clause 6.3.1, specifically addressing the “Protection of PII in the cloud,” mandates that cloud service providers (CSPs) implement appropriate technical and organizational measures to protect PII. This includes ensuring that PII is not processed or transferred without proper authorization, and that it is handled in accordance with the data subject’s rights and applicable legal frameworks, such as the GDPR or CCPA. The standard emphasizes the importance of transparency and accountability in how PII is managed. When a CSP receives a request from a supervisory authority or a data subject regarding their PII, the CSP must have established procedures to respond effectively and in compliance with legal obligations. This involves identifying the relevant PII, understanding the nature of the request (e.g., access, rectification, erasure), and coordinating with the customer (the data controller) to fulfill the request. The CSP’s role is to facilitate the data subject’s rights and comply with regulatory inquiries, acting as a processor on behalf of the controller. Therefore, the most appropriate action for the CSP, when faced with a direct request from a data subject concerning their PII held within the cloud service, is to inform the customer (data controller) and collaborate to address the request. This upholds the principle of shared responsibility and ensures that the controller, who has the primary relationship with the data subject, is involved in the response.

The core principle being tested here is the cloud customer’s responsibility for defining and enforcing PII processing policies within the public cloud environment, as stipulated by ISO 27018:2019. Specifically, the standard emphasizes that the cloud service provider (CSP) acts as a data processor, and the cloud service customer (CSC) is the data controller. Therefore, the CSC retains the ultimate responsibility for ensuring that the PII processed within the cloud environment complies with applicable data protection laws and regulations, such as the GDPR or CCPA. This includes defining the purposes and means of processing, establishing data retention periods, and implementing appropriate security controls. While the CSP provides the infrastructure and certain security measures, the CSC must actively configure and manage these services to meet its specific PII protection requirements. The scenario highlights a situation where the CSP’s default settings might not align with the CSC’s stringent PII handling obligations, necessitating proactive configuration and oversight by the customer. The correct approach involves the customer actively defining and implementing their data protection policies, rather than solely relying on the CSP’s general security posture or assuming the CSP will automatically adhere to specific regulatory nuances without explicit instruction and configuration. This proactive stance is crucial for demonstrating accountability and compliance.

The core principle being tested here is the cloud customer’s responsibility for the security of their data within the public cloud environment, specifically concerning Personally Identifiable Information (PII). ISO 27018:2019, while establishing a framework for cloud service providers (CSPs) to protect PII processed on their behalf, does not absolve the customer (data controller) of their fundamental obligations. The standard emphasizes a shared responsibility model. The customer remains accountable for defining the scope of PII, determining appropriate security controls, and ensuring compliance with relevant data protection regulations, such as the GDPR or CCPA, which often dictate data minimization, purpose limitation, and individual rights. The CSP’s role is to provide a secure infrastructure and services that enable the customer to meet these obligations. Therefore, the customer’s proactive engagement in defining data handling policies, conducting risk assessments, and implementing appropriate access controls for their PII within the cloud is paramount. The CSP’s adherence to ISO 27018:2019 provides assurance regarding their security practices, but the ultimate responsibility for the lawful and secure processing of PII rests with the customer.

The core principle being tested here is the shared responsibility model in cloud computing, specifically as it pertains to Personally Identifiable Information (PII) protection under ISO 27018:2019. The standard emphasizes that while the Cloud Service Provider (CSP) is responsible for the security of the cloud infrastructure, the customer (data controller/processor) retains responsibility for the PII they process within that cloud. This includes implementing appropriate controls for data classification, access management, encryption, and data lifecycle management for the data they upload and manage. The scenario highlights a situation where a CSP has implemented robust security for the underlying infrastructure, but the customer has failed to adequately secure the PII they have stored, leading to a breach. The question probes the understanding of where the primary accountability lies for the PII itself, irrespective of the infrastructure’s security. Therefore, the customer’s failure to implement specific PII protection measures for their data, such as encryption at rest or granular access controls for their specific data sets, is the direct cause of the PII exposure, even though the CSP’s infrastructure was not compromised. This aligns with the principles of data stewardship and the customer’s role in ensuring the confidentiality, integrity, and availability of their own data, as mandated by various data protection regulations like GDPR, which ISO 27018 complements. The CSP’s obligation is to provide a secure environment, but the customer must leverage that environment and implement their own controls for the data they own and process.

The core principle being tested here is the responsibility allocation for PII processing in a public cloud environment, specifically concerning the obligations of a cloud service provider (CSP) under ISO 27018:2019. The standard emphasizes that while the CSP is responsible for the security of the cloud infrastructure and the PII processed within it, the customer (data controller) retains ultimate responsibility for the lawful processing and protection of their PII. Therefore, when a customer requests the CSP to delete PII, the CSP’s obligation is to facilitate this deletion by providing the necessary mechanisms and confirming the action, but the ultimate assurance that all PII has been appropriately handled, including any residual copies or backups not directly managed by the CSP’s deletion process, rests with the customer. The customer must verify that their PII has been removed from all locations and systems under their purview, which might include their own cached data or applications interacting with the cloud service. The CSP’s role is to execute the deletion request as per agreed-upon service levels and security controls, but it does not absolve the customer of their data protection obligations under regulations like GDPR or CCPA, which mandate ensuring data minimization and the right to erasure.

The core principle being tested here is the distinction between the responsibilities of a cloud service provider (CSP) and a cloud service customer (CSC) concerning Personally Identifiable Information (PII) processing in a public cloud environment, as delineated by ISO 27018:2019. Specifically, the standard emphasizes that the CSP is responsible for the security and privacy of the PII processed on behalf of the customer within the cloud infrastructure. This includes implementing appropriate technical and organizational measures to protect the PII from unauthorized access, disclosure, alteration, or destruction. The customer, on the other hand, retains responsibility for defining the purpose and means of processing the PII, ensuring compliance with applicable data protection laws (such as GDPR or CCPA), and managing their own access controls and data handling practices within the cloud. Therefore, when a CSP is processing PII on behalf of a customer, the CSP’s obligation is to secure that data according to the standard’s controls, which are designed to protect PII in accordance with international privacy principles. The customer’s role is to ensure their own configurations and data usage align with legal requirements and their own privacy policies. The correct approach focuses on the CSP’s direct accountability for the security of the PII entrusted to its infrastructure, irrespective of the specific data content or the customer’s ultimate data controller status.

The question revolves around the contractual obligations of a cloud service provider (CSP) under ISO 27018:2019 when a data subject exercises their right to erasure, as mandated by regulations like GDPR. Specifically, it probes the CSP’s responsibility concerning the deletion of PII from backup and archival systems. ISO 27018:2019, Clause 7.3.2, addresses the CSP’s obligations regarding the retention and deletion of PII. While the standard emphasizes the CSP’s role in facilitating the customer’s (data controller’s) ability to fulfill data subject rights, it also outlines specific responsibilities for the CSP. When a data controller requests the deletion of PII, the CSP must ensure that this deletion is carried out across all systems under its control, including those used for backup and disaster recovery, unless legally prohibited or where retention is necessary for specific, documented purposes (e.g., regulatory compliance). The key is that the CSP must make reasonable efforts to ensure that the PII is not retained indefinitely in a retrievable state in these secondary systems. The standard implies that the CSP should have processes in place to manage data lifecycle, including secure deletion from backups within a reasonable timeframe or according to agreed-upon policies, balancing the right to erasure with operational necessities. Therefore, the CSP’s commitment to securely delete PII from backup and archival systems, subject to legal constraints and defined retention periods, is the most accurate reflection of its obligations.

The core principle being tested here is the cloud customer’s responsibility for data processing activities when using a public cloud service provider in the context of ISO 27018:2019. Specifically, the standard emphasizes that the cloud service provider (CSP) acts as a data processor on behalf of the cloud customer, who is typically the data controller. This division of roles dictates who is primarily accountable for ensuring compliance with data protection regulations, such as GDPR or CCPA, concerning the personal data processed. While the CSP must adhere to the commitments outlined in the standard and its agreement with the customer, the ultimate responsibility for the lawful processing of personal data, including obtaining consent, managing data subject rights, and conducting data protection impact assessments, rests with the customer. Therefore, the customer must actively manage and oversee the CSP’s processing activities to ensure they align with their own legal obligations and the principles of ISO 27018. This involves clear contractual arrangements, ongoing monitoring, and understanding the shared responsibility model. The customer’s proactive engagement is crucial for maintaining compliance and protecting the personal data entrusted to the cloud environment.

The core principle being tested here is the responsibility allocation for PII processing in a public cloud environment, specifically concerning the obligations of a cloud service provider (CSP) under ISO 27018:2019 when acting as a data processor. The standard emphasizes that the CSP, while processing PII on behalf of a customer (the data controller), must adhere to specific controls to protect that PII. Clause 6.1.1 of ISO 27018:2019 outlines the CSP’s commitment to protecting PII. When a customer requests the deletion of PII, the CSP’s obligation is to facilitate this deletion in accordance with the contractual agreement and applicable laws, which often include data retention periods mandated by regulations like GDPR or CCPA. However, the *ultimate responsibility* for ensuring that the deletion complies with all legal requirements, including any necessary archiving or specific retention periods, rests with the data controller (the customer). The CSP acts on the controller’s instructions. Therefore, the CSP’s role is to execute the deletion request, but the controller must verify that this execution meets all their legal and business obligations. This distinction is crucial for understanding the shared responsibility model in cloud security and privacy. The CSP is not expected to independently determine the legal necessity of retaining data beyond a customer’s deletion request; that judgment belongs to the controller.

The core principle being tested here is the responsibility of the cloud service provider (CSP) versus the cloud service customer (CSC) concerning the protection of Personally Identifiable Information (PII) in a public cloud environment, as delineated by ISO 27018:2019. Specifically, the standard emphasizes that while the CSP is responsible for the security of the cloud infrastructure and the services it provides, the CSC retains ultimate responsibility for the PII it processes and stores within that environment. This includes implementing appropriate controls for data classification, access management, and data lifecycle management. The scenario describes a situation where a CSP has implemented robust security measures for its infrastructure, which is a foundational requirement. However, the CSC has failed to adequately classify its data and implement granular access controls for its sensitive PII. Therefore, the primary deficiency lies with the CSC’s data handling practices, not the CSP’s infrastructure security. The correct approach focuses on the CSC’s obligation to manage its data lifecycle and access permissions, which is a direct implication of the shared responsibility model in cloud computing and a key tenet of ISO 27018:2019. The other options, while touching upon security concepts, misattribute the primary responsibility or focus on aspects that are not the root cause of the identified PII protection gap in this specific scenario. For instance, focusing solely on the CSP’s compliance with ISO 27018:2019 without addressing the CSC’s role in data management would be incomplete. Similarly, attributing the issue solely to the lack of a data breach notification policy overlooks the proactive measures needed to prevent such breaches in the first place, which is the CSC’s domain.

The core of ISO 27018:2019 is to provide guidance on the protection of Personally Identifiable Information (PII) in public cloud environments. A critical aspect of this standard is how it addresses the responsibilities of cloud service providers (CSPs) and cloud customers concerning PII. When a CSP processes PII on behalf of a cloud customer, the standard emphasizes that the CSP should only process PII according to the documented instructions of the cloud customer. This is a fundamental principle that underpins the entire framework of data protection in this context, ensuring that the CSP acts as a data processor and adheres to the data controller’s directives. This principle is directly linked to Clause 6.1.1 of ISO 27018:2019, which outlines the CSP’s obligations regarding PII processing. The standard also mandates that CSPs must not retain PII for longer than necessary for the purpose for which it was collected, and must ensure that any PII processed is accurate and up-to-date to the extent possible. Furthermore, the CSP must implement appropriate technical and organizational measures to protect PII against unauthorized or unlawful processing and against accidental loss, destruction or damage. The obligation to inform the cloud customer about any personal data breach is also a key component, ensuring transparency and enabling the customer to take necessary actions. Therefore, the most accurate statement reflecting the CSP’s primary obligation regarding PII processing, as per the standard, is to act solely on the documented instructions of the cloud customer.

The core of ISO 27018:2019 is to provide guidance on the protection of Personally Identifiable Information (PII) in public cloud environments. A key aspect of this standard is the shared responsibility model between the cloud service provider (CSP) and the cloud service customer (CSC). When a CSP processes PII on behalf of a CSC, the standard mandates specific controls and obligations. Clause 7.2.1 of ISO 27018:2019 outlines the CSP’s responsibilities concerning the disclosure of PII. Specifically, it requires the CSP to inform the CSC if it receives a legally binding request from a government or law enforcement authority for access to PII processed on behalf of the CSC. This notification is crucial for the CSC to exercise its rights and potentially challenge such requests, especially in light of differing international data protection laws like the GDPR or CCPA. The CSP’s obligation is to provide timely and relevant information to the CSC to enable the CSC to fulfill its own legal and regulatory obligations. This proactive communication is a cornerstone of trust and transparency in cloud PII processing. Therefore, the most accurate representation of the CSP’s duty under this clause is to inform the customer about such legal demands, allowing the customer to manage the situation.

The core principle being tested here is the responsibility shift for PII processing in a public cloud environment, specifically concerning the obligations of a cloud service provider (CSP) under ISO 27018:2019 when acting as a data processor. The standard emphasizes that while the CSP processes PII on behalf of the customer (the data controller), it must adhere to specific controls to protect that PII. Clause 6.1.1 of ISO 27018:2019 outlines the CSP’s obligations regarding the processing of PII. It states that the CSP shall process PII in accordance with the data controller’s instructions and relevant data protection legislation. Furthermore, ISO 27018:2019, Annex A, Control A.1.1.2, “Information security policy for PII,” mandates that the CSP shall establish and publish a policy for the protection of PII. This policy should address the CSP’s commitment to protecting PII and outline the responsibilities of its personnel. When a CSP offers services that involve processing PII, it is inherently acting as a data processor. Therefore, its contractual agreements and operational practices must reflect its role as a processor, ensuring that PII is handled in a manner consistent with the data controller’s instructions and applicable privacy laws, such as the GDPR or CCPA, which often dictate processor obligations. The CSP’s own internal security policies and controls must be aligned with these external requirements. The correct approach is to ensure that the CSP’s published PII protection policy explicitly acknowledges its role as a data processor and details how it will fulfill its obligations to protect PII according to the data controller’s instructions and relevant legal frameworks. This includes specifying how it will manage data subject rights requests, data breaches, and data transfers, all within the context of its processor role.

The core principle being tested here is the cloud customer’s responsibility for the security of their data within the public cloud environment, specifically concerning Personally Identifiable Information (PII). ISO 27018:2019, while providing a framework for cloud service providers (CSPs) to protect PII, does not absolve the customer of their fundamental obligations. The standard emphasizes a shared responsibility model. Clause 5.1.1 of ISO 27018:2019, “Information security policy for PII processing,” and related clauses on risk assessment and controls, implicitly place the onus on the customer to ensure that the PII they entrust to a CSP is handled in accordance with applicable laws and their own security policies. This includes understanding the CSP’s commitments and ensuring they align with the customer’s legal and regulatory obligations, such as those under GDPR or CCPA. The customer must actively manage their data, including its classification, access controls, and retention, even when processed by a third-party CSP. Therefore, the customer’s responsibility to define and enforce policies for PII processing, regardless of the CSP’s role, is paramount. This aligns with the broader concept of data governance and the principle that the data owner retains ultimate accountability for its protection.

The core principle being tested here is the responsibility shift for PII processing in a public cloud environment, specifically concerning the obligations of a cloud service provider (CSP) acting as a data processor under regulations like GDPR. ISO 27018:2019 Clause 6.1.2, “Responsibilities for PII,” addresses this. It mandates that a CSP, when processing PII on behalf of a customer (the data controller), must adhere to the customer’s instructions and applicable laws. The customer retains the primary responsibility for the lawful processing of PII. However, the CSP has specific obligations to assist the controller in fulfilling their duties, particularly concerning data subject rights and security measures.

When a data breach occurs that affects PII processed by the CSP, the CSP’s role is to provide the customer (the controller) with the necessary information to enable the controller to meet their own notification obligations under relevant data protection laws, such as Article 33 of the GDPR. This includes details about the nature of the breach, the categories and approximate number of data subjects concerned, and the likely consequences. The CSP is not typically the entity directly notifying the supervisory authority or the data subjects unless specifically contracted to do so, and even then, the ultimate accountability rests with the controller. Therefore, the CSP’s primary action is to facilitate the controller’s response by providing timely and accurate information. The other options represent either the controller’s primary responsibility, an overreach of the CSP’s role, or a less direct and immediate action required by the standard.

The core of ISO 27018:2019 is to establish controls for the protection of Personally Identifiable Information (PII) in public cloud environments. Clause 6.3.2, “Information transfer to other controllers,” specifically addresses the responsibilities when PII is transferred to another entity acting as a controller. This clause mandates that the cloud service provider (CSP) must ensure that the receiving controller is contractually obligated to provide the same level of protection for the PII as stipulated by the standard. This includes obtaining necessary consents, implementing appropriate security measures, and adhering to data subject rights. The question probes the understanding of this contractual obligation and the CSP’s responsibility in ensuring the continued protection of PII when it moves to another controlling entity within the cloud ecosystem. The correct response highlights the necessity of a contractual agreement that explicitly mandates the receiving controller to uphold the protection standards defined by ISO 27018, thereby ensuring continuity of data privacy. Other options are incorrect because they either misrepresent the nature of the obligation (e.g., focusing solely on notification without contractual assurance), suggest a lesser standard of protection, or imply a transfer of responsibility that absolves the original CSP of its due diligence.

The core principle being tested here is the cloud customer’s responsibility for defining and managing the scope of PII processing within the public cloud environment, as stipulated by ISO 27018:2019. Specifically, clause 5.1.1, “Identification of PII,” mandates that the cloud service customer (CSC) must identify the PII they intend to process in the public cloud. This identification is the foundational step for all subsequent security and privacy controls. Without the CSC clearly defining what constitutes PII for their specific context and how it will be processed, the cloud service provider (CSP) cannot effectively implement the necessary protections. The CSP’s role is to provide a secure environment and implement controls based on the information provided by the CSC. Therefore, the responsibility for the initial definition and classification of PII rests with the entity that controls the data – the customer. This aligns with the shared responsibility model in cloud computing, where the customer retains responsibility for data classification and management.

The core of ISO 27018:2019 is to provide guidance on the protection of Personally Identifiable Information (PII) in public cloud environments. A key aspect of this standard is how it addresses the responsibilities of both the cloud service provider (CSP) and the cloud service customer (CSC) concerning PII. Specifically, the standard emphasizes that the CSP is responsible for the security of the cloud infrastructure and the PII processed within it, while the CSC remains accountable for the PII they entrust to the cloud. When a CSP makes a commitment to a CSC regarding PII protection, this commitment is typically documented in the cloud service agreement or a Data Processing Addendum (DPA). This agreement should clearly delineate the roles and responsibilities, including how the CSP will assist the CSC in meeting its own legal and regulatory obligations for PII protection, such as those mandated by GDPR or similar data privacy laws. The standard does not mandate that the CSP directly assume the CSC’s legal liability for PII breaches. Instead, it focuses on the CSP’s obligations to implement appropriate technical and organizational measures to safeguard the PII and to provide transparency and assistance to the CSC. Therefore, the CSP’s primary obligation is to facilitate the CSC’s compliance by providing a secure environment and relevant information, not to absorb the CSC’s ultimate legal responsibility.

The core of ISO 27018:2019 is to establish controls for the protection of Personally Identifiable Information (PII) in public cloud environments. Clause 6.3.1 specifically addresses the “Protection of PII against unauthorized disclosure.” This clause mandates that the cloud service provider (CSP) must implement appropriate technical and organizational measures to prevent unauthorized access to or disclosure of PII processed on behalf of a customer. This includes, but is not limited to, access controls, encryption, and secure development practices. The scenario describes a situation where a CSP’s internal audit identifies a potential vulnerability in a legacy system that could lead to unauthorized access to customer PII if exploited. The immediate and most critical action, aligned with the principles of ISO 27018:2019, is to contain the risk by isolating the affected system to prevent any further exposure or exploitation. This aligns with the proactive and risk-mitigation approach required by the standard. Other actions, such as notifying customers or performing a full forensic analysis, are important follow-up steps but do not represent the immediate, primary control action to prevent further compromise. The standard emphasizes a layered security approach, where immediate containment is paramount in such identified risks.

The core principle being tested here is the cloud customer’s responsibility in managing PII within a public cloud environment, specifically in relation to ISO 27018:2019. The standard delineates responsibilities between the cloud service provider (CSP) and the cloud service customer (CSC). While the CSP is responsible for the security of the cloud infrastructure and the PII processing activities they perform on behalf of the customer, the customer retains ultimate accountability for the PII they entrust to the cloud. This includes ensuring that the PII processed, stored, and transmitted is done so in compliance with applicable data protection laws and regulations, such as the GDPR or CCPA. The customer must implement appropriate controls and policies to govern the PII lifecycle, including data minimization, purpose limitation, consent management, and data subject rights. Therefore, even when leveraging a CSP, the customer’s obligation to protect PII remains paramount and is not entirely delegated. The customer’s role is proactive, requiring them to understand the CSP’s security posture and to configure their cloud services in a manner that upholds their data protection commitments. The correct approach involves the customer actively managing their data governance and security configurations within the cloud.