The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning PII. ISO 27018:2019, in conjunction with relevant data protection regulations like the GDPR, emphasizes that while the cloud service provider (CSP) is responsible for the security of the cloud infrastructure and services, the customer (data controller) retains ultimate responsibility for the lawful processing of PII. This includes ensuring that the CSP’s controls and practices align with the customer’s data protection obligations, particularly when PII is transferred or processed outside the customer’s primary jurisdiction. The customer must conduct due diligence to verify that the CSP’s commitments, as outlined in contractual agreements and privacy policies, adequately protect PII in accordance with applicable laws, such as those governing cross-border data transfers and data subject rights. Therefore, the customer’s proactive verification of the CSP’s compliance with ISO 27018:2019 controls and relevant legal frameworks is paramount. This involves understanding the CSP’s data handling practices, security measures, and contractual assurances related to PII protection, especially when the CSP acts as a data processor on behalf of the customer. The customer’s obligation extends to ensuring that any sub-processors engaged by the CSP also adhere to these standards.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning the protection of personally identifiable information (PII). ISO 27018:2019 emphasizes a shared responsibility model. While the cloud service provider (CSP) is responsible for the security *of* the cloud infrastructure, the customer remains responsible for the security *in* the cloud, which includes the PII they process and store. This encompasses defining the purpose and means of processing, ensuring compliance with relevant data protection regulations (like GDPR or CCPA), and implementing appropriate controls for the PII they manage. The scenario highlights a situation where the CSP has implemented robust security measures for the cloud environment itself. However, the customer’s failure to adequately classify and apply specific access controls to sensitive PII data, even within a secured environment, constitutes a gap in their own responsibilities as a data controller or processor. Therefore, the correct approach focuses on the customer’s proactive measures in data classification and access management, which are fundamental to fulfilling their obligations under ISO 27018:2019 and related privacy laws. The other options represent either the CSP’s responsibilities or a misunderstanding of the customer’s role in managing their own data within the cloud.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning the protection of Personally Identifiable Information (PII) as outlined in ISO 27018:2019. Clause 6.2.1 of the standard emphasizes the cloud customer’s obligation to define and implement controls for the processing of PII. This includes ensuring that the cloud service provider (CSP) is contractually bound to adhere to the customer’s specified PII processing requirements. The scenario describes a situation where a CSP’s standard terms of service might not adequately address the specific PII protection mandates of a particular jurisdiction or the customer’s internal policies. Therefore, the customer must actively ensure that the CSP’s practices align with their own responsibilities. This involves a proactive review and potential amendment of contractual agreements to explicitly cover data handling, consent management, and data subject rights, all of which are critical for compliance with regulations like GDPR or CCPA. The responsibility for ensuring that the PII is processed in accordance with the customer’s legal and policy obligations rests with the customer, even when utilizing a CSP. The CSP acts as a data processor on behalf of the customer, who is the data controller. The customer must therefore verify that the processor’s actions meet the controller’s obligations.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning the protection of Personally Identifiable Information (PII) as outlined in ISO 27018:2019. The standard emphasizes a shared responsibility model. While the cloud service provider (CSP) is responsible for the security of the cloud infrastructure and services, the customer retains ultimate responsibility for the PII they process and store. This includes defining the purpose and means of processing, ensuring compliance with relevant data protection regulations (like GDPR, CCPA, etc.), and implementing appropriate controls for the PII itself. Therefore, when a cloud customer engages a CSP to process PII, the customer must ensure that the CSP’s practices align with their own data protection obligations and the requirements of ISO 27018. This involves due diligence, contractual agreements, and ongoing monitoring. The customer’s role is not merely to delegate but to actively manage and oversee the processing of their PII, even when it occurs within the CSP’s environment. This proactive stance is crucial for maintaining accountability and ensuring the confidentiality, integrity, and availability of PII.

The core principle being tested here is the responsibility of the Cloud Service Provider (CSP) concerning the processing of Personally Identifiable Information (PII) on behalf of a Cloud Service Customer (CSC) under ISO 27018:2019. Specifically, the standard emphasizes that the CSP should not process PII for its own purposes or in a manner inconsistent with the CSC’s instructions, unless legally mandated. When a CSP receives a request from a government or law enforcement agency for PII, it must, to the extent legally permissible, inform the CSC of the request. This notification allows the CSC to challenge the request or seek protective measures. The CSP’s obligation is to act in accordance with the CSC’s instructions and applicable laws, prioritizing transparency with the customer. Therefore, the most appropriate action is to notify the CSC, unless legally prohibited from doing so. This aligns with the standard’s intent to ensure the CSC retains control and awareness over its PII.

The core principle being tested here is the cloud customer’s responsibility for the security of their data when using a public cloud service provider, specifically in the context of ISO 27018:2019. The standard outlines a shared responsibility model. While the cloud service provider (CSP) is responsible for the security *of* the cloud infrastructure, the customer remains responsible for the security *in* the cloud, which includes the data they process and store. This encompasses implementing appropriate access controls, encryption, data classification, and ensuring compliance with relevant data protection regulations like GDPR or CCPA. The scenario describes a situation where a cloud customer is migrating sensitive personal data. The responsibility for ensuring that this data is protected according to the customer’s own policies and legal obligations, even though it resides on the CSP’s infrastructure, rests with the customer. This involves understanding and configuring the security features provided by the CSP and potentially augmenting them with their own security measures. The CSP’s role is to provide a secure environment and tools, but the ultimate accountability for data protection, including the implementation of specific controls for PII, lies with the data controller, which is the customer in this context. Therefore, the customer must actively manage and verify the security posture of their data within the cloud environment.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning the protection of Personally Identifiable Information (PII). ISO 27018:2019 emphasizes a shared responsibility model. While the Cloud Service Provider (CSP) is responsible for the security of the cloud infrastructure and the services they offer, the cloud customer retains ultimate accountability for the PII they entrust to the cloud. This includes ensuring that the PII is processed in accordance with applicable data protection laws and regulations, such as the GDPR or CCPA, and that the CSP’s controls are adequate for their specific data processing needs. The customer must conduct due diligence, establish appropriate contractual agreements, and implement their own security measures to protect the PII. Therefore, the customer’s obligation to ensure compliance with relevant data protection legislation for the PII they process in the cloud is paramount and non-delegable to the CSP. The CSP’s role is to provide the necessary security features and assurances, but the ultimate responsibility for the lawful and secure processing of PII rests with the customer.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning PII. ISO 27018:2019, in conjunction with relevant data protection regulations like GDPR, emphasizes that while the cloud service provider (CSP) is responsible for the security of the cloud infrastructure, the customer (data controller) retains ultimate responsibility for the PII they entrust to the cloud. This includes ensuring that the CSP’s practices align with the customer’s legal obligations and that appropriate contractual agreements are in place. The customer must actively manage and oversee how their PII is processed, stored, and transferred, even when delegated to a third-party CSP. This involves understanding the CSP’s security controls, data handling policies, and their compliance posture. Therefore, the customer’s proactive engagement in defining and enforcing data protection measures, including the right to audit and verify compliance, is paramount. The scenario highlights a common misconception where reliance on the CSP’s certifications alone is deemed sufficient, neglecting the customer’s inherent obligations as a data controller. The correct approach necessitates a comprehensive understanding of shared responsibility models and the customer’s active role in safeguarding PII.

The core principle being tested here is the cloud customer’s responsibility in managing PII when the cloud service provider (CSP) acts as a data processor. ISO 27018:2019, particularly in Annex A, emphasizes the shared responsibility model. When a CSP processes PII on behalf of a customer, the customer retains accountability for the PII. This includes ensuring that the CSP’s controls are adequate and that the processing aligns with applicable data protection laws, such as the GDPR. The customer must therefore conduct due diligence and establish contractual agreements that clearly define roles, responsibilities, and the specific security measures the CSP will implement to protect the PII. The customer’s obligation extends to understanding how their PII is handled, stored, and potentially transferred by the CSP, and to ensuring that these operations meet the required standards of protection. This proactive engagement and verification are crucial for maintaining compliance and safeguarding the PII entrusted to the cloud environment. The correct approach involves a thorough assessment of the CSP’s security posture and contractual commitments to ensure they align with the customer’s legal and ethical obligations regarding PII.

The core principle being tested here is the responsibility of the cloud service provider (CSP) concerning the processing of personally identifiable information (PII) on behalf of a customer, as stipulated by ISO 27018:2019. Specifically, the standard emphasizes that the CSP should not process PII for its own purposes or in a manner inconsistent with the customer’s instructions or applicable laws. When a CSP receives a request from a government or law enforcement agency for PII, it must first verify the legal basis for the request. If the request is legally binding and the CSP is permitted to disclose information, it should then inform the customer (the data controller) about the request, unless prohibited by law. This notification allows the customer to challenge the request or take other appropriate actions. Therefore, the CSP’s obligation is to facilitate the customer’s control over their data, even when faced with external legal demands, by providing transparency and an opportunity to respond, unless legally constrained from doing so. The scenario describes a CSP that directly complies with a government request without informing the customer, which is a deviation from the expected protocol for handling such requests under the standard’s framework, particularly concerning the customer’s right to know and potentially contest the disclosure.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning the protection of personally identifiable information (PII). ISO 27018:2019 emphasizes a shared responsibility model. While the cloud service provider (CSP) is responsible for the security *of* the cloud infrastructure, the customer remains responsible for the security *in* the cloud, which includes how they configure and manage their data processing activities. When a cloud customer engages a CSP to process PII on their behalf, the customer, as the data controller, retains ultimate accountability for ensuring that the PII is processed in accordance with applicable regulations and the principles outlined in ISO 27018. This includes defining the purposes and means of processing, and ensuring the CSP’s controls are adequate for those purposes. The customer must therefore actively manage and oversee the CSP’s adherence to these requirements, rather than simply delegating the entire responsibility. This proactive oversight is crucial for maintaining compliance with regulations like GDPR, which places direct obligations on data controllers regarding the processing of personal data, including when it is handled by third-party processors. The customer’s role is not passive; it involves due diligence, contractual agreements, and ongoing monitoring to ensure the CSP’s practices align with the customer’s data protection obligations.

The core principle being tested here is the cloud customer’s responsibility in managing data security and privacy when using a public cloud service provider, specifically in the context of ISO 27018:2019. The standard emphasizes a shared responsibility model. While the cloud service provider (CSP) is responsible for the security *of* the cloud infrastructure, the customer (the data controller or processor) retains responsibility for the security *in* the cloud, which includes the data itself, its classification, access controls, and how it is processed and handled.

Consider a scenario where a cloud customer, “Aethelred Analytics,” is processing sensitive personal data of EU citizens within a public cloud environment. Aethelred Analytics has implemented robust technical controls on the cloud infrastructure provided by their CSP, such as encryption at rest and in transit, and has configured network security groups. However, they have not established a clear data retention policy for the personal data stored in the cloud, nor have they conducted a data protection impact assessment (DPIA) as required by regulations like the GDPR for processing high-risk personal data. Furthermore, they have not adequately trained their personnel on the specific privacy obligations related to cloud-based data processing, leading to an instance where an employee inadvertently shares an anonymized dataset with an unauthorized third party due to a misunderstanding of data handling procedures.

The question probes which of these actions or inactions most directly contravenes the principles of ISO 27018:2019 concerning the customer’s role in protecting PII. The standard, in conjunction with relevant data protection laws, mandates that the customer actively manage and govern the PII they entrust to the cloud. This includes understanding data flows, implementing appropriate controls based on risk assessments, and ensuring compliance with legal requirements. The failure to conduct a DPIA and establish data retention policies, coupled with inadequate personnel training on privacy-specific cloud handling, represents a significant gap in the customer’s responsibility for the *management* and *governance* of PII within the cloud environment. These are direct responsibilities of the data controller/processor, not typically outsourced to the CSP under ISO 27018. The CSP’s role is to provide a secure platform and adhere to its own contractual and standard obligations, but the ultimate accountability for data protection, including policy development and risk assessment, rests with the customer. Therefore, the absence of a DPIA and data retention policies, alongside insufficient training, highlights a fundamental failure in the customer’s proactive data protection strategy as envisioned by ISO 27018:2019 and related privacy regulations.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning the protection of personally identifiable information (PII) as mandated by ISO 27018:2019. Clause 6.3.1 of the standard, titled “Customer responsibilities,” emphasizes that the cloud service customer (CSC) retains ultimate responsibility for the PII it entrusts to the cloud service provider (CSP). This includes ensuring that the CSP’s controls are adequate for the specific PII processing activities and that the CSC’s own policies and procedures align with the CSP’s capabilities and the relevant legal and regulatory frameworks. The scenario highlights a situation where a CSP has implemented robust security measures, but the CSC has failed to adequately define its data retention policies for PII, leading to potential non-compliance with data protection laws like GDPR. The correct approach involves the CSC proactively establishing and communicating clear data retention and deletion requirements to the CSP, ensuring these are reflected in the contractual agreements and operational procedures. This proactive stance is crucial because the CSP’s role is to provide the infrastructure and services, but the CSC dictates *how* the PII is processed, including its lifecycle management. The other options represent a misunderstanding of this shared responsibility model. Focusing solely on the CSP’s certifications, assuming the CSP will automatically manage all PII lifecycle aspects without explicit instruction, or delegating the entire responsibility for PII protection to the CSP without due diligence, all fall short of the CSC’s obligations under ISO 27018:2019 and relevant data protection legislation. The standard requires the CSC to actively manage and oversee its PII within the cloud environment.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning the protection of Personally Identifiable Information (PII). ISO 27018:2019 emphasizes a shared responsibility model. While the Cloud Service Provider (CSP) is responsible for the security of the cloud infrastructure and the services they offer, the customer (the data controller or processor) retains ultimate accountability for how PII is processed, stored, and managed within that cloud environment. This includes defining the purposes and means of processing, ensuring compliance with relevant data protection regulations (such as GDPR or CCPA), and implementing appropriate security controls for the data itself. The customer’s role is not merely passive; they actively direct and oversee the processing of PII. Therefore, the customer is fundamentally responsible for ensuring that the processing of PII aligns with legal requirements and the principles outlined in ISO 27018, even when utilizing a CSP’s services. This encompasses aspects like data minimization, purpose limitation, and the rights of data subjects, all of which are directed by the customer.

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 a Cloud Service Provider (CSP) handles PII when it is transferred to or processed in a jurisdiction with different data protection laws. The standard emphasizes that the CSP must ensure that the level of protection for PII is maintained, regardless of the geographical location of data processing. This involves understanding the legal and regulatory landscape of both the originating and destination countries. When PII is transferred to a third country, the CSP must implement appropriate safeguards to ensure compliance with applicable data protection principles, such as those found in regulations like the GDPR (General Data Protection Regulation) or similar national laws. These safeguards can include contractual clauses, binding corporate rules, or other mechanisms recognized by relevant authorities. The standard also mandates transparency with the customer regarding data transfers and the associated risks. Therefore, the most appropriate action for a CSP when PII is transferred to a third country with potentially weaker data protection is to ensure that the transfer is conducted in compliance with the legal framework governing the PII, which necessitates implementing recognized safeguards to maintain an equivalent level of protection. This aligns with the principle of accountability and the need to demonstrate due diligence in data protection.

The core principle being tested here is the cloud customer’s responsibility for defining the scope of Personally Identifiable Information (PII) processing within the cloud service, as stipulated by ISO 27018:2019. Clause 6.1.1, “Identification of PII,” mandates that the cloud customer, as the data controller, must clearly identify the PII it intends to process in the public cloud. This includes specifying the types of PII, the purposes of processing, and the legal basis for such processing. The cloud service provider (CSP) then uses this information to implement appropriate security controls. Therefore, the responsibility for defining the PII processing scope rests with the customer, not the CSP or any external regulatory body in the first instance of defining what constitutes PII for their specific context within the cloud. The CSP’s role is to facilitate the secure processing of the PII as defined by the customer, adhering to the standard’s controls.

The core principle being tested here is the responsibility of the Cloud Service Provider (CSP) concerning the processing of Personally Identifiable Information (PII) on behalf of a Cloud Service Customer (CSC) in the context of ISO 27018:2019. Specifically, it addresses the CSP’s obligations when PII is transferred to or processed in a jurisdiction with different data protection laws than the originating jurisdiction. ISO 27018:2019, clause 6.3.3, titled “Protection of PII when transferring PII to other jurisdictions,” mandates that the CSP shall ensure that PII processed on behalf of a CSC is protected in accordance with the CSC’s instructions and applicable laws, even when transferred to other jurisdictions. This includes implementing appropriate safeguards to ensure a level of protection essentially equivalent to that provided in the originating jurisdiction. This often involves contractual agreements, technical measures, and organizational policies that align with relevant data protection regulations, such as the GDPR or similar national laws, which often require specific mechanisms for cross-border data transfers to maintain adequate protection. Therefore, the CSP must proactively identify and mitigate risks associated with jurisdictional differences in data protection, rather than solely relying on the CSC to manage these risks or assuming that existing controls are sufficient without verification. The CSP’s role is to provide assurances and implement controls that facilitate compliant cross-border processing.

The core principle being tested here is the cloud customer’s responsibility in managing the security of personal data when utilizing cloud services, specifically in the context of ISO 27018:2019. The standard emphasizes a shared responsibility model. While the cloud service provider (CSP) is responsible for the security *of* the cloud infrastructure, the cloud customer retains responsibility for the security *in* the cloud, which includes the proper configuration and management of the services they use to process personal data. This encompasses implementing appropriate access controls, data encryption strategies, and ensuring that the data processing activities align with relevant data protection regulations like GDPR. The scenario highlights a situation where the CSP has provided a secure platform, but the customer’s own internal data handling practices and the configuration of their cloud-based data processing environment are the root cause of a potential breach. Therefore, the customer’s proactive measures and ongoing oversight of their data processing activities are paramount. The correct approach involves the customer ensuring their data classification, access management policies, and incident response plans are robust and effectively implemented within the cloud environment, rather than solely relying on the CSP’s baseline security.

The core principle being tested here is the responsibility of the Cloud Service Provider (CSP) concerning the processing of Personally Identifiable Information (PII) on behalf of a Cloud Service Customer (CSC) in the context of ISO 27018:2019. Specifically, the standard emphasizes that the CSP should not process PII for its own purposes or in a manner that contradicts the CSC’s instructions or applicable data protection laws. Clause 6.2.1 of ISO 27018:2019 states that the CSP shall not process PII beyond what is necessary to provide the cloud computing services, and shall not use PII for its own purposes without the explicit consent of the CSC. Furthermore, the CSP must adhere to the data protection laws of the jurisdiction where the PII originates or is processed. In this scenario, the CSP’s internal marketing department’s use of anonymized customer data for targeted advertising, even if anonymized, could be construed as processing for the CSP’s own purposes, which requires explicit consent and careful consideration of anonymization techniques to ensure re-identification is not possible, aligning with the principles of data minimization and purpose limitation. The most appropriate response directly addresses the CSP’s obligation to obtain explicit consent for any processing beyond service provision and to ensure compliance with relevant data protection regulations. This aligns with the CSP’s role as a data processor acting on behalf of the data controller (the CSC).

The core principle being tested here is the cloud customer’s responsibility for data processing activities when using a public cloud service provider, specifically in the context of ISO 27018:2019. The standard emphasizes that while the cloud service provider (CSP) is responsible for the security of the cloud infrastructure and services, the customer retains ultimate responsibility for the PII they entrust to the cloud. This includes ensuring that the PII is processed lawfully, fairly, and transparently, and that appropriate security measures are in place for the data itself, not just the underlying infrastructure. The customer must also ensure that the CSP’s practices align with their own legal and regulatory obligations, such as those stemming from GDPR or similar data protection laws. Therefore, the customer’s obligation to ensure the lawful processing of PII, including obtaining necessary consents and providing data subject rights, remains paramount, irrespective of the CSP’s security controls. The customer must actively manage and oversee these aspects, rather than passively relying on the CSP’s general assurances. This proactive stance is crucial for demonstrating compliance and mitigating risks associated with PII in the cloud environment.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning the protection of personally identifiable information (PII) in accordance with ISO 27018:2019. Clause 6.1.1 of the standard, “Identification of PII Processing,” mandates that the cloud service customer (CSC) must identify and document all PII processing activities undertaken within the cloud service. This includes understanding the types of PII processed, the purposes of processing, and the legal basis for such processing. When a CSC engages a cloud service provider (CSP) to process PII on their behalf, the CSC retains ultimate accountability for ensuring that the processing aligns with applicable data protection laws and regulations, such as the GDPR or CCPA, and the principles outlined in ISO 27018. Therefore, the CSC must actively confirm that the CSP’s controls and practices adequately support the CSC’s own compliance obligations. This involves understanding the shared responsibility model and ensuring that the CSP’s commitments, as documented in agreements and attestations, meet the CSC’s specific PII protection requirements. The CSC cannot delegate its fundamental responsibility for data protection compliance to the CSP.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning the protection of Personally Identifiable Information (PII) as outlined in ISO 27018:2019. Clause 5.1.1 of the standard emphasizes the cloud customer’s role in defining the purposes and means of processing PII. While the cloud service provider (CSP) offers the infrastructure and services, the customer remains accountable for how PII is handled, including its collection, storage, processing, and deletion. Therefore, the customer must ensure that their chosen cloud services and their own configurations and operational practices align with applicable data protection laws, such as the GDPR or CCPA, and the requirements of ISO 27018. The CSP’s role is to provide a secure environment and specific controls that the customer can leverage, but the ultimate responsibility for the lawful and secure processing of PII rests with the customer. This includes understanding the data flows, implementing appropriate access controls, and ensuring data minimization.

The core principle being tested here relates to the responsibilities of a Cloud Service Provider (CSP) under ISO 27018:2019 when a data breach involving Personally Identifiable Information (PII) occurs. Specifically, the standard emphasizes the CSP’s obligation to notify the customer (the data controller) and, where applicable, relevant supervisory authorities, without undue delay. The explanation of the correct approach involves understanding that the CSP’s primary duty is to inform the customer, who then typically handles the broader notification process, potentially including regulatory bodies like those under GDPR. The CSP’s role is to provide the necessary information to facilitate this. The other options represent either an overreach of the CSP’s direct responsibility (e.g., directly notifying all affected individuals without customer consent or instruction), an underestimation of the CSP’s duty (e.g., only notifying the customer after a significant delay or not at all), or a misinterpretation of the notification chain of custody (e.g., directly notifying regulatory bodies before or instead of the customer). The standard mandates prompt communication to the data controller to enable timely and appropriate action.

The core principle being tested here is the cloud customer’s responsibility for the security of their data within the cloud environment, specifically concerning Personally Identifiable Information (PII) as governed by ISO 27018:2019. While the cloud service provider (CSP) is responsible for the security *of* the cloud infrastructure, the customer retains responsibility for the security *in* the cloud, which includes the configuration, access controls, and encryption of their PII. When a CSP offers a service that allows for the deletion of PII, and the customer requests this deletion, the CSP must ensure that the PII is irretrievably removed from all systems under their control. However, the standard acknowledges that certain PII might be retained for legal or regulatory compliance reasons. In such cases, the CSP must inform the customer about the retention period and the reasons for it. The customer, in turn, must be aware of these retained data points and their purpose. Therefore, the most accurate statement reflects the shared responsibility model and the specific obligations of the CSP regarding notification of retained data post-deletion request. The correct approach involves understanding that the CSP’s obligation is to securely delete or anonymize PII, and if retention is necessary, to provide clear notification to the customer about the nature, purpose, and duration of that retention, aligning with the customer’s own compliance obligations.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning the protection of personally identifiable information (PII). ISO 27018:2019 emphasizes a shared responsibility model. While the cloud service provider (CSP) is responsible for the security of the cloud infrastructure and the services they offer, the customer retains ultimate accountability for the PII they process and store. This includes ensuring that the PII is processed lawfully, fairly, and transparently, and that appropriate security measures are in place for the data itself, regardless of where it resides. The customer must also ensure compliance with relevant data protection regulations, such as GDPR or CCPA, which often impose direct obligations on data controllers. Therefore, the customer’s obligation to ensure that PII is processed in accordance with applicable laws and regulations, and that appropriate security controls are applied to the PII, remains paramount. This encompasses the customer’s role in defining data retention policies, managing access to PII, and responding to data subject rights requests, all of which are outside the direct operational control of the CSP. The customer’s due diligence in selecting a compliant CSP and their ongoing monitoring of the CSP’s adherence to contractual and regulatory requirements are also critical components of this responsibility.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud, specifically concerning the protection of Personally Identifiable Information (PII) as outlined in ISO 27018:2019. Clause 6.1.1 of the standard emphasizes the cloud customer’s obligation to define and implement controls for PII processing. When a cloud customer engages a cloud service provider (CSP) to process PII, the customer retains accountability for ensuring that the processing aligns with applicable privacy regulations and the requirements of ISO 27018. This includes establishing the purpose and means of processing, which are fundamental to the customer’s role as a data controller or equivalent. The CSP, in this context, acts as a data processor. Therefore, the customer must ensure that the CSP’s controls, as documented in their service agreements and attestations, are sufficient to meet the customer’s own obligations. This involves due diligence in selecting a CSP and ongoing monitoring of their compliance. The responsibility for defining the scope and purpose of PII processing, and ensuring that the processing is lawful and secure, rests with the customer, even when leveraging cloud services.

The core principle being tested here is the cloud customer’s responsibility for data processing activities within the public cloud environment, specifically concerning the protection of personally identifiable information (PII) as outlined in ISO 27018:2019. The standard emphasizes a shared responsibility model, but crucially, the customer retains ultimate accountability for how their PII is processed and managed. This includes ensuring that the cloud service provider’s (CSP) practices align with the customer’s legal and regulatory obligations, such as those imposed by GDPR or similar data protection frameworks. When a CSP is engaged in processing PII on behalf of a customer, the customer must have mechanisms in place to verify the CSP’s compliance and to ensure that the processing is lawful, fair, and transparent. This verification is not a one-time event but an ongoing assurance process. The customer’s contractual agreements with the CSP should clearly define roles, responsibilities, and audit rights. Furthermore, the customer must be able to demonstrate to supervisory authorities that they have taken all necessary steps to ensure the PII entrusted to the CSP is adequately protected. This involves understanding the CSP’s security controls, data handling policies, and incident response capabilities, and ensuring these meet the customer’s own risk appetite and compliance requirements. The customer’s obligation extends to understanding where the PII is stored and processed, and if cross-border transfers are involved, ensuring appropriate safeguards are in place. Therefore, the continuous assurance of the CSP’s adherence to data protection principles, as mandated by ISO 27018:2019 and relevant data protection laws, is paramount for the customer.

The core principle being tested here is the responsibility of the Cloud Service Provider (CSP) regarding the processing of Personally Identifiable Information (PII) on behalf of a Cloud Service Customer (CSC) in the context of ISO 27018:2019. Specifically, the standard emphasizes that the CSP should not process PII for its own purposes, nor should it transfer PII to unauthorized third parties without explicit instruction from the CSC. The scenario describes a situation where a CSP, without direct instruction from the CSC, uses PII data stored in the cloud for its own marketing analytics. This action directly contravenes the obligations outlined in ISO 27018:2019, particularly concerning the control and use of PII. The CSP is acting as a data processor for the CSC, and its actions must be governed by the CSC’s instructions and the contractual agreements, which should align with the principles of ISO 27018. The standard mandates that CSPs must ensure that PII is processed only according to the CSC’s instructions and applicable laws. Using PII for independent marketing analytics, even if anonymized or aggregated, without the CSC’s consent or a clear legal basis, represents a breach of trust and a violation of the CSP’s role as a processor. Therefore, the most appropriate response is that the CSP’s actions are inconsistent with its obligations under ISO 27018:2019, as it is processing PII for purposes not authorized by the Cloud Service Customer. This aligns with the standard’s emphasis on accountability and the CSP acting solely as a data processor under the CSC’s direction.

The core principle being tested here is the responsibility of the Cloud Service Provider (CSP) concerning the processing of Personally Identifiable Information (PII) on behalf of a Cloud Service Customer (CSC) in the context of ISO 27018:2019. Specifically, it addresses the CSP’s obligations when PII is transferred to or processed in a jurisdiction with different data protection laws. ISO 27018:2019, Clause 6.5.2, titled “Protection of PII in transit,” mandates that the CSP shall ensure that PII is protected during transmission, whether within or outside the cloud service. Furthermore, Clause 6.5.3, “Protection of PII during processing,” requires the CSP to implement appropriate controls to protect PII from unauthorized access, disclosure, alteration, or destruction. When PII is transferred to a jurisdiction with less stringent data protection laws, the CSP has a direct obligation to implement additional safeguards to ensure the PII receives a level of protection consistent with the originating jurisdiction’s requirements and the principles of ISO 27018:2019. This often involves contractual agreements, technical measures like encryption, and ensuring that the processing in the new jurisdiction adheres to the defined security policies. The scenario describes a situation where a CSP is moving PII to a country with weaker data protection, and the correct action is to implement enhanced controls to maintain the required protection level, aligning with the standard’s intent to safeguard PII regardless of location. The other options represent actions that are either insufficient, outside the CSP’s direct responsibility in this context, or misinterpret the standard’s requirements for cross-border data transfers of PII.

The core principle being tested here is the cloud customer’s responsibility in managing the security of their Personally Identifiable Information (PII) when using a public cloud service provider, specifically in the context of ISO 27018:2019. The standard emphasizes a shared responsibility model. While the cloud service provider (CSP) is responsible for the security *of* the cloud infrastructure, the customer is responsible for the security *in* the cloud. This includes how they configure access controls, manage encryption keys, and implement data loss prevention mechanisms for the PII they store and process. Therefore, the customer must actively implement and manage controls to protect PII, rather than solely relying on the CSP’s baseline security measures. The correct approach involves the customer taking proactive steps to secure their data, such as implementing robust access management policies, employing client-side encryption where appropriate, and conducting regular security assessments of their cloud environment. This aligns with the shared responsibility model where the CSP provides a secure foundation, but the customer builds and secures their specific workloads and data upon it.