The question concerns the implementation of ISO/IEC 27017:2015 controls within a cloud service provider operating in Connecticut, particularly concerning the responsibilities for data security. ISO/IEC 27017:2015 provides guidance on information security controls applicable to the provision and use of cloud services. A key aspect of this standard is the delineation of responsibilities between the cloud service provider (CSP) and the cloud service customer (CSC). Control A.6.1.1, “Information security policy,” is fundamental, but the specific control addressing the CSP’s role in managing and securing the cloud infrastructure itself, which is directly relevant to a CSP operating in Connecticut and subject to potential regulatory oversight, is A.8.1.2. This control mandates that the CSP establish and implement a policy for the secure use of cloud services. This policy should cover aspects like access control, data segregation, and incident management within the CSP’s managed environment. The scenario describes a CSP in Connecticut that has not clearly defined its responsibilities for securing the underlying cloud infrastructure, leading to potential data breaches. The most appropriate control to address this fundamental gap in responsibility and policy for a CSP is A.8.1.2, which focuses on the CSP’s policy for secure use of cloud services, encompassing the infrastructure they manage. While other controls like A.9.1.1 (Access control policy) or A.12.1.1 (Operational procedures and responsibilities) are relevant, A.8.1.2 directly targets the overarching policy framework for the CSP’s own operational security of the cloud environment. The prompt specifically asks about the CSP’s responsibilities for securing the cloud infrastructure.

The question probes the application of ISO/IEC 27017:2015 controls in a cross-border cloud service context, specifically concerning data protection obligations that might arise from a Connecticut-based entity interacting with a cloud service provider located within the European Union, and how this intersects with potential EU data privacy regulations. ISO/IEC 27017:2015 provides guidance on information security controls for cloud services. A key aspect is the shared responsibility model in cloud computing, where both the cloud service customer and the cloud service provider have distinct security responsibilities. When a Connecticut entity (subject to US laws, including potentially state-specific data privacy laws like those being developed or enacted in various US states) engages a cloud service provider in the EU, the provider is subject to the General Data Protection Regulation (GDPR) if it processes personal data of EU residents. Even if the Connecticut entity’s data is not personal data of EU residents, the provider’s operational environment and security practices are governed by EU regulations and standards. Control A.9.1.2, “Access control to information and information processing facilities,” is directly relevant. This control mandates that access to information and information processing facilities is restricted to authorized users, business functions, and processes. In a cross-border scenario involving an EU-based provider, this means the provider must implement robust access controls that align with both their internal policies and any applicable regulatory requirements, including those that may stem from the GDPR’s principles of data minimization and purpose limitation, even if indirectly. The scenario highlights the need for the Connecticut entity to ensure its contractual agreements with the EU provider clearly define responsibilities and that the provider’s access control mechanisms are sufficient to protect data, regardless of its origin, in accordance with international best practices and relevant legal frameworks. The control’s effectiveness is paramount in preventing unauthorized access and ensuring data integrity and confidentiality.

The question probes the practical application of ISO/IEC 27017:2015 controls within a cross-border cloud service context, specifically touching upon the interplay between data protection obligations in Connecticut and the EU’s General Data Protection Regulation (GDPR). While Connecticut has enacted its own data privacy laws, such as the Connecticut Data Privacy Act (CTDPA), and is influenced by broader US federal and state privacy trends, the GDPR’s extraterritorial reach means that entities processing the personal data of EU residents, even if located in Connecticut, must comply with its provisions. ISO/IEC 27017:2015 provides a framework for information security controls for cloud services. Control A.8.2.3, “Protection of information in the public cloud,” is particularly relevant here. It mandates that customers and cloud service providers must agree on the responsibilities for protecting information in the public cloud. When a Connecticut-based cloud service provider offers services to clients in the EU, the provider must ensure its security controls align with the data protection requirements stipulated by both Connecticut law and the GDPR, where applicable. This includes, but is not limited to, implementing appropriate technical and organizational measures to ensure a level of security appropriate to the risk, as required by GDPR Article 32. The agreement between the provider and the customer, as per A.8.2.3, must clearly delineate these responsibilities, ensuring that the provider’s security posture supports the customer’s compliance with GDPR, especially concerning data subject rights, data breach notification, and lawful processing. The focus is on the contractual and operational alignment of security practices with legal mandates, not on the legal status of the cloud service provider itself in relation to EU law per se, but on the security measures that enable compliance.

The scenario involves a Connecticut-based technology firm, “Nutmeg Cloud Solutions,” which offers Software as a Service (SaaS) to clients across the European Union. Nutmeg Cloud Solutions is obligated to comply with the General Data Protection Regulation (GDPR) for any personal data processed on behalf of its EU clients. ISO/IEC 27017:2015 provides a framework for information security controls for cloud services. When a cloud service customer (in this case, an EU entity) delegates the management of certain security controls to the cloud service provider (Nutmeg Cloud Solutions), the responsibility for implementing and maintaining those controls shifts. Specifically, according to ISO/IEC 27017:2015, Annex A, control A.6.1.2, “Information security for use of cloud services,” clarifies that the responsibilities for information security controls should be defined in an agreement between the cloud service provider and the cloud service customer. This agreement should clearly delineate which party is responsible for which security controls, especially those related to the shared responsibility model inherent in cloud computing. Given that Nutmeg Cloud Solutions is the provider and its EU clients are the customers, the firm must ensure that its service agreements explicitly outline the security responsibilities for data processed within its cloud environment, aligning with GDPR’s data protection principles and ISO 27017’s guidance on shared responsibilities. The most appropriate action for Nutmeg Cloud Solutions to ensure compliance and clarity, particularly concerning data processed on behalf of EU clients, is to establish a comprehensive data processing agreement that explicitly defines the division of security responsibilities between the firm and its clients, reflecting the shared responsibility model of cloud services as detailed in ISO/IEC 27017:2015. This agreement would encompass controls related to access management, data encryption, incident response, and data deletion, all of which are critical for GDPR compliance and secure cloud operations.

The question concerns the application of ISO/IEC 27017:2015 controls in a cross-border cloud service context, specifically involving a Connecticut-based company and a cloud service provider (CSP) operating within the European Union. The core issue is ensuring that the CSP’s data handling practices align with the stringent requirements of the General Data Protection Regulation (GDPR), which is a primary concern for any organization processing personal data of EU residents, regardless of their own location. ISO/IEC 27017 provides a framework for information security controls for cloud services. Specifically, Annex A of ISO/IEC 27001, which is referenced and extended by ISO/IEC 27017, includes controls related to access control, cryptography, and supplier relationships. When a Connecticut company utilizes a CSP within the EU, the company, as a data controller, remains responsible for ensuring that its data processors (the CSP) comply with GDPR. This includes implementing appropriate technical and organizational measures to protect personal data. ISO/IEC 27017:2015, control A.8.2.3 (Protection of information in cloud services), mandates that the CSP should implement controls to protect information processed in the cloud. For a Connecticut company interacting with an EU-based CSP, the most critical aspect is the CSP’s adherence to GDPR principles, which are often operationalized through controls aligned with international standards like ISO/IEC 27017. The CSP’s commitment to GDPR compliance, demonstrated through certifications or contractual clauses that incorporate GDPR-relevant security measures, is paramount. This ensures that the personal data of EU citizens, which might be processed by the Connecticut company’s cloud service, is handled in accordance with the GDPR’s requirements for data security and privacy. The specific control that most directly addresses the protection of information within the cloud service context, and by extension, the CSP’s responsibility under GDPR, is the implementation of appropriate security measures to protect the confidentiality, integrity, and availability of information processed in the cloud. This encompasses both technical and organizational measures.

The question concerns the application of ISO/IEC 27017:2015 controls within a cloud service context, specifically focusing on the responsibilities of a cloud service customer in relation to data protection and access management. ISO/IEC 27017 provides guidance on information security controls for cloud services, building upon ISO/IEC 27002. It clarifies responsibilities for both cloud service providers (CSPs) and cloud service customers (CSCs). A critical aspect of this standard is the demarcation of responsibilities, particularly concerning data processed in the cloud. Control A.6.1.1, “Information security policies,” emphasizes the need for policies that address cloud services, and A.8.1.2, “Cloud service agreements,” mandates clear agreements on responsibilities. In the scenario presented, the CSC is responsible for managing user access to their data stored within the cloud. This includes defining roles, granting permissions, and revoking access when necessary. While the CSP manages the underlying infrastructure and security of the cloud environment, the CSC retains accountability for the data itself and who can access it. Therefore, the CSC’s primary responsibility related to user access to their data in the cloud environment, as per ISO/IEC 27017, is to implement appropriate access control mechanisms and policies for their users. This aligns with the principles of data ownership and the shared responsibility model inherent in cloud computing.

The question concerns the application of ISO/IEC 27017:2015 controls within a cloud service context, specifically focusing on the responsibilities of a cloud service customer when engaging with a cloud service provider. ISO/IEC 27017:2015 delineates shared responsibility models for information security in cloud computing. Control A.5.1.1, titled “Information security policies,” mandates that the organization (in this case, the cloud service customer) establish and maintain a set of information security policies. For a cloud service customer, this involves defining and implementing policies that address the specific risks associated with using cloud services. This includes specifying how the customer will manage their responsibilities in the shared security model, such as access control to cloud resources, data classification within the cloud environment, and incident management procedures that interface with the provider’s processes. The customer’s internal policies must clearly outline the security measures they will undertake to protect their data and operations within the cloud, irrespective of the provider’s controls. The other options represent different aspects of cloud security or information security in general, but do not directly address the fundamental requirement for the customer to establish their own security policies tailored to their cloud usage as per A.5.1.1. For instance, A.8.2.1 concerns user access management, which is a component of the customer’s policy but not the overarching policy requirement itself. A.10.1.1 deals with cryptography, a technical control, not a policy framework. A.13.1.1 relates to network security, another technical domain. Therefore, the most accurate and encompassing control for the customer’s foundational security posture in a cloud environment, as per ISO/IEC 27017:2015, is the establishment of their own information security policies.

The scenario involves a Connecticut-based cloud service provider, “Nutmeg Cloud Solutions,” which is subject to both US federal regulations and the General Data Protection Regulation (GDPR) due to its processing of personal data of EU residents. ISO/IEC 27017:2015 provides guidance on information security controls for cloud services, specifically addressing the shared responsibility model between cloud service providers and cloud service customers. When a cloud service provider like Nutmeg Cloud Solutions offers services to customers who are themselves subject to GDPR, the provider must implement controls that facilitate the customer’s compliance. Specifically, the question probes the provider’s responsibility under ISO/IEC 27017:2015 concerning data breach notification, a critical aspect of GDPR. While GDPR mandates that the data controller (the customer) must notify supervisory authorities and data subjects of a breach without undue delay, the cloud service provider plays a crucial role in enabling this notification. ISO/IEC 27017:2015, in Annex A.18.1.3 (Information security incident management), emphasizes the need for organizations to establish a process for reporting security incidents. For cloud services, this extends to providing timely and relevant information to the customer to assist them in meeting their own legal obligations, including breach notification timelines. Therefore, the provider’s obligation is to have mechanisms in place to detect, report, and communicate security incidents to the customer promptly, allowing the customer to fulfill their GDPR-mandated notification duties. The provider’s internal procedures for incident handling and communication are paramount.

The core of ISO/IEC 27017:2015, particularly in the context of cloud services, revolves around defining responsibilities for information security controls between a cloud service provider (CSP) and a cloud service customer (CSC). This standard builds upon ISO/IEC 27002 by providing guidance specifically tailored for cloud environments. When a CSP offers services, it retains responsibility for certain controls, while the CSC is responsible for others, depending on the service model (IaaS, PaaS, SaaS) and the specific control. For instance, physical security of the data center facilities is typically the CSP’s responsibility, whereas user access management within the customer’s virtual environment is the CSC’s. The standard emphasizes the importance of clearly documenting and communicating these shared responsibilities through a service agreement or similar contractual mechanism. This clarity is crucial for effective risk management and ensuring that all necessary security measures are implemented. Without this explicit delineation, there’s a significant risk of security gaps, where neither party assumes responsibility for a particular aspect of security, leading to potential vulnerabilities. Therefore, understanding and implementing this shared responsibility model is paramount for any organization utilizing cloud services and seeking to adhere to robust information security practices. The question probes the foundational principle of how responsibilities are allocated in a cloud security framework guided by ISO/IEC 27017, specifically focusing on the contractual aspect that formalizes this division.

The question concerns the application of ISO/IEC 27017:2015 controls in a cloud computing context, specifically relating to the shared responsibility model between a cloud service provider (CSP) and a cloud service customer (CSC). The scenario describes a data breach affecting sensitive customer data stored on a cloud platform. ISO/IEC 27017:2015, a code of practice for information security controls based on ISO/IEC 27002 for cloud services, emphasizes the delineation of responsibilities. Control A.7.1.1, “Information security policy for cloud services,” mandates that both the CSP and CSC establish and maintain an information security policy for cloud services that addresses their respective responsibilities. In this case, the CSC, a financial institution operating in Connecticut, is responsible for implementing controls related to data classification, access management, and incident response for the data it entrusts to the CSP. The breach occurred due to an improperly configured access control mechanism that was the direct responsibility of the CSC to manage and monitor. Therefore, the most appropriate control from ISO/IEC 27017:2015 that the CSC failed to adequately implement, leading to the breach, is related to access control management and monitoring, specifically within the CSC’s purview. Considering the options, A.9.2.3 “Access control for privileged accounts” and A.9.4.1 “Information access restriction” are highly relevant. However, A.9.4.1 directly addresses the principle of restricting access to information based on business and security requirements, which was clearly violated by the misconfiguration. The CSP has responsibilities for the security of the underlying infrastructure, but the CSC is responsible for the security of the data itself and how it is accessed within the cloud environment. The failure to implement A.9.4.1 would manifest as unauthorized access, as seen in the scenario.

The core principle tested here relates to the contractual responsibilities and liabilities between a cloud service customer and a cloud service provider concerning data protection and security, specifically within the framework of ISO/IEC 27017:2015. The standard delineates shared responsibilities. Clause 5.3.1.1 of ISO/IEC 27017:2015, titled “Information security policy for cloud services,” emphasizes the need for clear agreements. Specifically, it states that “The organization should establish and document a cloud computing security policy that addresses the specific security requirements of cloud computing and the responsibilities of the cloud service provider and the customer.” Furthermore, Annex A.5.3.1.1 provides guidance on the content of such policies, including the allocation of responsibilities. When a cloud service provider fails to implement appropriate access controls and audit logging for customer data stored on their infrastructure, and this failure leads to a data breach, the provider is typically held accountable for the controls that fall within their purview as defined by the service agreement and the ISO standard. The customer, in this scenario, would be responsible for managing their own user access and data classification, but the underlying infrastructure security and logging are the provider’s domain. Therefore, the provider’s breach of their contractual and standard-defined obligations regarding access controls and logging directly causes the data compromise. The question probes the understanding of where liability rests when a cloud service provider’s specific control failures, as outlined by ISO 27017, result in a security incident affecting a customer’s data. The correct answer reflects the provider’s responsibility for the security of the underlying infrastructure and the logging mechanisms, which were demonstrably inadequate in this case, leading to the breach.

The question probes the understanding of the interplay between ISO/IEC 27017:2015 controls and the contractual obligations of cloud service providers (CSPs) under European Union data protection law, specifically the General Data Protection Regulation (GDPR). While ISO/IEC 27017:2015 provides a framework for information security controls for cloud services, including those related to access control and incident management, the GDPR imposes specific obligations on data controllers and processors regarding the security of personal data. When a CSP processes personal data on behalf of a controller, the contractual agreement must ensure that the CSP implements appropriate technical and organizational measures to protect the data. In the context of a data breach, the GDPR, particularly Article 33 and Article 34, mandates notification requirements for personal data breaches. Article 33 requires the controller to notify the supervisory authority without undue delay and, where feasible, not later than 72 hours after having become aware of it, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons. Article 34 outlines the circumstances under which data subjects must be notified. ISO/IEC 27017:2015, through controls like A.12.4.1 (Logging), A.12.4.3 (Monitoring), and A.16.1.1 (Reporting information security events), supports the detection and investigation of incidents that could lead to a breach. However, the specific legal obligation to notify the supervisory authority and data subjects within defined timeframes is a GDPR requirement, not directly codified with specific timelines within ISO/IEC 27017:2015 itself, which focuses on controls rather than regulatory reporting deadlines. Therefore, while the ISO standard facilitates the detection and response, the legal duty to notify is a distinct GDPR mandate that must be contractually reinforced. The scenario describes a CSP identifying a potential data breach and initiating an internal investigation. The critical aspect is the CSP’s obligation to inform the data controller promptly so that the controller can meet their GDPR notification obligations. The GDPR’s emphasis on timely notification means that the CSP’s internal processes, guided by ISO 27017, must enable swift reporting to the controller.

The scenario describes a situation where a cloud service provider (CSP) operating within Connecticut, and offering services to EU citizens, must adhere to specific data protection principles. The core issue is how the CSP’s internal data handling practices align with the requirements of ISO/IEC 27017:2015, particularly concerning the shared responsibility model in cloud security. ISO/IEC 27017:2015 provides guidance on information security controls for cloud services, emphasizing the delineation of responsibilities between the cloud service customer and the cloud service provider. When a CSP processes personal data of EU residents, even if the CSP itself is based in the US, it falls under the purview of the EU’s General Data Protection Regulation (GDPR) if it targets EU individuals. While the question focuses on ISO 27017, the underlying principle of shared responsibility is paramount. ISO/IEC 27017:2015, specifically in clauses related to access control, cryptography, and incident management, highlights the CSP’s obligations. The question asks about the most appropriate action for the CSP to ensure compliance with ISO 27017:2015, given its role as a provider. The correct approach involves clearly defining and communicating its security responsibilities within the contractual agreement with its clients. This aligns with the standard’s intent to manage security risks effectively in a cloud environment by establishing clear lines of accountability. Other options, such as solely relying on client-side controls, unilaterally imposing strict controls without client agreement, or focusing only on US domestic regulations, would fail to address the specific requirements of ISO 27017:2015 and its implications for cloud service security, especially when international data flows are involved. The standard requires a proactive and collaborative approach to security management in the cloud.

The scenario describes a situation where a cloud service provider (CSP) operating within Connecticut, and offering services to EU citizens, is seeking to comply with ISO/IEC 27017:2015. This standard provides guidance on information security controls for cloud services, building upon ISO/IEC 27002. Specifically, the question focuses on the CSP’s responsibility in relation to data subject rights under the GDPR, which is a critical aspect for any entity processing personal data of EU residents. ISO/IEC 27017:2015, in Annex A.18.1.4, addresses “Protection of information relevant to contractual arrangements with customers,” which includes obligations arising from privacy and data protection laws. While ISO/IEC 27017 doesn’t directly implement GDPR articles, it guides the implementation of controls that support compliance. For a CSP, this means establishing mechanisms to facilitate data subject requests, such as access, rectification, erasure, and data portability. The most direct control for enabling data subject rights, particularly the right to erasure (Article 17 of GDPR), would involve the CSP having the capability to securely delete or anonymize data upon a customer’s instruction, which in turn would be passed on from the data subject. Therefore, the CSP’s ability to support the “right to be forgotten” through secure data deletion or anonymization processes is a fundamental requirement. This aligns with the broader principles of data protection by design and by default mandated by the GDPR. The CSP must have technical and organizational measures in place to ensure that data can be permanently removed or rendered unidentifiable when requested by the data subject, acting through the data controller (the customer).

The core of ISO/IEC 27017:2015 is to provide guidance on information security controls for cloud services, building upon the foundational ISO/IEC 27002. When considering the shared responsibility model inherent in cloud computing, the standard emphasizes the delineation of responsibilities between the cloud service provider (CSP) and the cloud service customer (CSC). Specifically, regarding the management of virtual computing resources, ISO/IEC 27017:2015 assigns the responsibility for the security of the underlying infrastructure, including the physical security of data centers and the hypervisor layer, to the CSP. Conversely, the CSC is primarily responsible for the security of the operating system, applications, and data deployed within their virtual environment. This division is crucial for establishing clear accountability and ensuring comprehensive security coverage. Therefore, in the context of a Connecticut-based company utilizing a public cloud service, the responsibility for securing the virtual machine’s operating system, including patch management and access controls for the OS, rests with the customer. The cloud service provider is accountable for the security of the physical infrastructure and the virtualization platform itself. This understanding is fundamental to implementing effective security strategies in cloud environments.

The scenario describes a cloud service provider operating within Connecticut that handles personal data of EU citizens. The provider is implementing security controls based on ISO/IEC 27017:2015, specifically focusing on the responsibilities of the cloud service provider in relation to customer data. The question asks to identify the most appropriate control from ISO/IEC 27017:2015 that addresses the provider’s obligation to manage and secure customer data in the cloud environment, considering the shared responsibility model. Control A.8.1.2, “Information Classification,” is fundamental because it establishes a framework for categorizing information based on its sensitivity and value, which directly informs the level of protection required. This classification is crucial for the cloud service provider to understand what specific security measures are needed for different types of customer data they process, thereby enabling them to meet their contractual and legal obligations, including those potentially stemming from EU data protection regulations that might be indirectly relevant to a Connecticut-based provider handling EU citizen data. Without proper classification, other controls related to access management, encryption, or incident response would be applied inconsistently or ineffectively. Therefore, establishing a clear information classification scheme is the foundational step for a cloud service provider to manage its responsibilities under ISO/IEC 27017:2015 and to ensure appropriate security measures are in place for customer data.

The question pertains to the application of ISO/IEC 27017:2015 controls within the context of cloud service provision, specifically focusing on the responsibilities of both the cloud service provider (CSP) and the cloud service customer (CSC) regarding asset management. ISO/IEC 27017:2015, a code of practice for information security controls based on ISO/IEC 27002 for cloud services, clarifies shared responsibilities. Control A.8.1.1, “Inventory of assets,” mandates that all information and other associated assets used in, supporting, or related to the provision of cloud services should be identified, documented, and maintained. In a cloud environment, the CSP is fundamentally responsible for the inventory of its own infrastructure and the underlying services it offers. The CSC, however, is responsible for the inventory of its own data, applications, and user access within the cloud environment. When considering shared responsibility for the inventory of assets that are *part of the cloud service offering itself*, the primary responsibility for documenting and managing the CSP’s infrastructure, including virtual machines, storage instances, and network configurations that constitute the cloud service, rests with the CSP. The CSC’s responsibility is to understand and manage the assets it deploys onto that infrastructure. Therefore, the CSP bears the primary responsibility for the inventory of the cloud infrastructure assets it provides to customers.

The core principle being tested here is the application of ISO/IEC 27017:2015 controls in a cross-border cloud service context, specifically concerning data breach notification obligations. While the General Data Protection Regulation (GDPR) is a prominent EU law, Connecticut, as a US state, operates under its own data privacy laws and potentially has agreements or considerations regarding EU data processing. ISO/IEC 27017:2015 provides a framework for information security controls for cloud services, including aspects related to incident management and breach notification. Control A.18.1.3, “Protection of records,” is relevant as it mandates the protection of records of information security incidents. However, the specific timing and content of notifications to supervisory authorities and data subjects are primarily governed by data protection regulations like the GDPR, or state-specific breach notification laws. In this scenario, the client is based in Connecticut, and the cloud service provider is processing personal data of individuals residing within the EU. Therefore, the provider must comply with both the GDPR’s notification requirements for EU data subjects and any applicable Connecticut data breach notification laws for its Connecticut-based clients. The question probes the understanding of which regulatory framework dictates the primary notification timelines and content when dealing with a breach affecting EU data subjects, even when the service provider is located in the US. The GDPR mandates notification to the supervisory authority without undue delay, and where feasible, not later than 72 hours after having become aware of it, and notification to the data subject without undue delay if the breach is likely to result in a high risk to their rights and freedoms. While Connecticut law also has breach notification requirements, the GDPR’s provisions are paramount for the EU data subjects’ information rights in this cross-border scenario. Thus, adherence to the GDPR’s 72-hour timeline for supervisory authority notification and subsequent data subject notification is the critical factor for the EU data.

The question revolves around the application of ISO/IEC 27017:2015 controls in a cross-border cloud service scenario, specifically concerning data breach notification and responsibilities between a cloud service customer (CSC) and a cloud service provider (CSP). In this context, the CSC, operating within Connecticut, experiences a data breach affecting personal data of EU citizens. ISO/IEC 27017:2015, specifically clause 6.8.2, addresses incident management and reporting. While the standard provides a framework for information security controls in cloud services, it does not supersede or dictate specific legal notification obligations. The General Data Protection Regulation (GDPR) of the European Union mandates notification to supervisory authorities within 72 hours of becoming aware of a personal data breach, and to data subjects without undue delay if the breach is likely to result in a high risk to their rights and freedoms. Given that the breach affects EU citizens’ personal data, the GDPR notification requirements are paramount. The CSP, even if based in the United States, is subject to these regulations if it processes personal data of EU residents. Therefore, the primary obligation for timely notification, irrespective of contractual agreements between the CSC and CSP that might specify different timelines or procedures, falls on the entity aware of the breach and its potential impact, which in this case is the CSC. The CSC must ensure compliance with GDPR’s stringent timelines. The most appropriate action for the CSC, upon becoming aware of the breach affecting EU citizens’ data, is to initiate the GDPR-mandated notification process to the relevant EU supervisory authority without delay, adhering to the 72-hour timeframe. Contractual clauses between the CSC and CSP regarding breach notification are secondary to legal obligations.

The scenario describes a situation where a cloud service provider (CSP) operating in Connecticut, which also offers services to entities within the European Union, needs to ensure compliance with both US data protection regulations and EU data protection principles, specifically concerning the handling of personal data in the cloud. ISO/IEC 27017:2015 provides a framework of information security controls for cloud services, building upon ISO/IEC 27002. When a CSP is processing personal data of EU residents, even if the CSP is based in Connecticut, the General Data Protection Regulation (GDPR) applies. Article 28 of the GDPR outlines the obligations of data processors, including the requirement to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. ISO/IEC 27017 directly supports this by providing specific guidance on cloud security controls, such as those related to asset management, access control, cryptography, and business continuity, which are essential for protecting personal data. Specifically, control A.8.2.3 of ISO/IEC 27017, “Information security for use of cloud services,” emphasizes the responsibilities of both the cloud service customer and the cloud service provider in defining and implementing security controls. For a CSP processing EU personal data, aligning their security practices with ISO/IEC 27017, particularly concerning shared responsibilities and data deletion, is crucial for demonstrating compliance with GDPR’s Article 28 requirements for processor obligations and for ensuring the security of personal data throughout its lifecycle, including its secure deletion upon termination of service, as mandated by GDPR’s right to erasure. Therefore, the CSP must focus on implementing controls that address the shared responsibility model and ensure data lifecycle management, including secure deletion, in accordance with both ISO/IEC 27017 and GDPR.

The core principle being tested here is the application of ISO/IEC 27017:2015 controls in a cross-border cloud service context, specifically concerning data breach notification and the interplay between EU data protection law and international standards. While the Connecticut European Union Law Exam focuses on the legal framework of the EU, the practical implementation of security controls like those in ISO/IEC 27017 directly impacts compliance with regulations such as the GDPR. The scenario involves a cloud service provider based in Connecticut that processes personal data of EU citizens. A data breach occurs, affecting this data. The provider must adhere to the notification requirements. ISO/IEC 27017:2015, specifically control A.18.1.4 (Legal, statutory, regulatory and contractual requirements), mandates that organizations identify and maintain an inventory of applicable legal, statutory, regulatory and contractual requirements for information security and privacy. For a service provider handling EU data, this inherently includes the GDPR. Article 33 of the GDPR requires data controllers to notify the supervisory authority of a personal data breach without undue delay, and where feasible, not later than 72 hours after having become aware of it, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons. If the breach is likely to result in a high risk, the controller must also communicate the personal data breach to the data subject without undue delay. ISO/IEC 27017:2015, while not a direct legal statute, provides a framework for implementing security controls that support compliance with such legal obligations. Therefore, the most appropriate control objective and related control from ISO/IEC 27017 that directly addresses the need to inform relevant parties about a security incident, in line with GDPR mandates, is related to the management of information security incidents. Specifically, control A.16.1.7 (Reporting of information security events) from ISO/IEC 27002 (which ISO/IEC 27017 builds upon) and its application within the cloud context as guided by ISO/IEC 27017, emphasizes the reporting of security events. While ISO/IEC 27017 doesn’t dictate the exact content of the notification, it mandates the establishment of processes for handling security events, which includes reporting. The question asks which aspect of ISO/IEC 27017 is most directly aligned with the *obligation to inform* affected parties about a breach, which is a key component of GDPR compliance. This aligns with the principle of ensuring that information security policies and procedures are established, implemented, reviewed, and maintained to ensure the correct and effective security of information. Specifically, the controls related to incident management and legal compliance are paramount. Control A.16.1.7 (Reporting of information security events) in ISO/IEC 27002, and its cloud-specific considerations within ISO/IEC 27017, directly address the reporting of security incidents. The prompt focuses on the *obligation to inform*, which is a consequence of a security event. Therefore, the control that deals with the reporting of such events is the most relevant. The scenario implies a breach has occurred, and the provider needs to act. The most direct application of ISO/IEC 27017 in this context, supporting the GDPR’s notification requirements, is ensuring that the provider has mechanisms to report incidents, which inherently includes informing relevant parties as legally mandated.

The scenario describes a situation where a cloud service provider, operating in Connecticut and offering services to entities within the European Union, is audited. The audit focuses on their adherence to information security controls relevant to cloud environments. ISO/IEC 27017:2015 provides a framework for information security controls for cloud services, building upon ISO/IEC 27002. Specifically, it addresses the shared responsibilities between cloud service providers and cloud service customers. Clause 5.3 of ISO/IEC 27017:2015, titled “Information security for cloud services,” outlines the responsibilities of both parties. For a cloud service provider, this includes implementing controls to protect the cloud service and the data processed within it, particularly when data is processed by the customer in the cloud. The provider must ensure appropriate security measures are in place for the underlying infrastructure and any services they manage. The question probes the provider’s responsibility in ensuring the security of data processed by the customer, which falls under the provider’s obligation to secure the cloud service itself. This involves implementing controls that support the customer’s security objectives, even if the customer configures specific aspects. The correct option reflects the provider’s duty to implement security measures that enable the customer to meet their own obligations.

The scenario describes a situation where a cloud service provider, operating within Connecticut and offering services to EU-based clients, is subject to various regulatory frameworks. The question probes the provider’s responsibility for ensuring compliance with ISO/IEC 27017:2015, specifically concerning the shared responsibility model in cloud security. ISO/IEC 27017:2015 outlines controls for information security for cloud services. In the context of a cloud service provider (CSP) and a cloud service customer (CSC), the responsibility for implementing security controls is shared. The standard explicitly addresses this by defining responsibilities for both parties. For controls related to the management of virtual computing resources, network infrastructure, and the physical security of data centers, the CSP typically holds the primary responsibility. However, the CSC also has responsibilities, such as managing access to virtual machines and configuring security settings within their virtual environment. When a CSP fails to implement controls related to the foundational infrastructure and the underlying cloud environment, and this failure leads to a data breach affecting EU citizens’ personal data, the CSP is directly liable for its part of the shared responsibility. This is because the CSP’s obligations under ISO/IEC 27017, when adopted or referenced by regulations like GDPR (which applies to data of EU citizens regardless of where the processing occurs), are to secure the cloud infrastructure. A failure in the CSP’s domain, such as inadequate protection of the hypervisor or network segmentation, directly breaches these obligations. The question asks about the direct liability of the CSP for its specific control failures. Therefore, the CSP is directly liable for its failure to implement and maintain security controls related to the foundational cloud infrastructure and services it provides.

The question pertains to the application of ISO/IEC 27017:2015 controls within a cloud service provider’s operational framework, specifically concerning the responsibilities of both the cloud service provider and the cloud customer. ISO/IEC 27017:2015 provides guidance on information security controls for cloud services, building upon ISO/IEC 27002. It clarifies the shared responsibility model inherent in cloud computing. In this scenario, a cloud customer, “NovaTech Solutions,” is using a cloud service from “AetherCloud,” a provider. NovaTech is concerned about the security of its sensitive data, particularly regarding access control and logging for virtual machines they manage within AetherCloud’s infrastructure. AetherCloud, as the cloud service provider, is responsible for the security *of* the cloud, which includes the underlying infrastructure, physical security, and network security up to the hypervisor layer. NovaTech, as the cloud customer, is responsible for security *in* the cloud, which encompasses the operating systems, applications, data, and access management within the virtual machines they provision and manage. Therefore, for the specific controls related to virtual machine access logging and user access management within those virtual machines, NovaTech is directly responsible for their implementation and oversight. This aligns with the principles outlined in ISO/IEC 27017:2015, specifically controls related to access control (e.g., A.9 in ISO/IEC 27002, adapted for cloud) and logging (e.g., A.12 in ISO/IEC 27002, adapted for cloud). The responsibility for configuring and reviewing logs for user activities within the virtual machines, and for managing user access to these virtual machines, rests with NovaTech as the entity controlling the virtual machine environment.

The question concerns the application of ISO/IEC 27017:2015 controls within a cloud computing context, specifically focusing on the responsibilities of a cloud service customer. In a shared responsibility model, the cloud service customer is primarily responsible for managing and securing the data they entrust to the cloud. This includes implementing access controls, ensuring data encryption, and managing user identities and access rights. While the cloud service provider (CSP) is responsible for the security of the underlying cloud infrastructure, the customer retains accountability for the security *in* the cloud. Therefore, when considering controls related to customer data, the focus shifts to the customer’s actions. Specifically, control A.8.1.2, “Access Control,” in ISO/IEC 27002, which is extended by ISO/IEC 27017:2015 for cloud services, emphasizes the customer’s role in defining and enforcing access rights to their cloud-based information assets. This involves establishing policies for user access, authentication mechanisms, and privilege management for data residing within the cloud environment. The customer’s responsibility for data classification and handling, as well as ensuring the integrity and confidentiality of their data through appropriate configurations and security measures, is paramount. The scenario highlights the customer’s obligation to implement these measures to comply with the standard.

The scenario describes a situation where a cloud service provider, operating within Connecticut and offering services to EU-based clients, must ensure compliance with both US federal data privacy regulations and EU data protection laws, specifically the General Data Protection Regulation (GDPR), in the context of cloud security controls as outlined by ISO/IEC 27017:2015. The core of the question revolves around the principle of accountability for data breaches. Under ISO/IEC 27017:2015, specifically in section 6.1.3 “Information security incident management,” it mandates that organizations establish and maintain a process for managing information security incidents, including prompt reporting and investigation. When a cloud service provider experiences a breach affecting personal data of EU citizens, the GDPR (Article 33) requires notification to the supervisory authority without undue delay, and where feasible, not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Furthermore, Article 34 of the GDPR mandates notification to the data subject without undue delay if the breach is likely to result in a high risk. The provider’s contractual obligations with its clients, who are data controllers, will also dictate specific reporting timelines and procedures, often mirroring or exceeding GDPR requirements. Therefore, the most appropriate action is to immediately initiate an investigation and prepare for mandatory notifications as stipulated by the applicable data protection frameworks, acknowledging that the specific timing and content of notifications will depend on the investigation’s findings regarding the scope and impact of the breach. The emphasis is on proactive management and transparent communication, aligning with the principles of data protection by design and by default, and the accountability principle inherent in both GDPR and robust information security management systems like ISO 27001 and its cloud extension ISO 27017.

The question pertains to the application of ISO/IEC 27017:2015, a code of practice for information security controls relevant to cloud services, within the context of a hypothetical cross-border data processing scenario involving a Connecticut-based company and a cloud service provider located in the European Union. The core issue is determining which of the listed controls from ISO/IEC 27017:2015 would be most critical for the Connecticut company to ensure compliance with data protection principles when data is processed by the EU cloud provider. ISO/IEC 27002 provides a baseline for information security controls, and ISO/IEC 27017 extends this specifically for cloud environments, addressing unique risks and responsibilities of cloud service providers and cloud customers. In this scenario, the Connecticut company is the cloud customer. The primary concern for a cloud customer is ensuring the security and privacy of their data as handled by the cloud service provider. ISO/IEC 27017:2015 introduces controls specifically designed for the shared responsibility model in cloud computing. Control A.8.1.3, “Information security for use of cloud services,” is paramount. This control mandates that the cloud customer should ensure that appropriate information security policies and procedures are established and implemented for the use of cloud services. This includes understanding the provider’s security measures, defining responsibilities, and ensuring data is handled in accordance with contractual agreements and relevant regulations. While other controls like A.5.1.1 (Policies for information security) or A.9.1.2 (Access control to program source code) are important for general information security and cloud environments respectively, A.8.1.3 directly addresses the customer’s responsibility to manage security when outsourcing to a cloud provider, which is the central theme of the question. The ability to monitor the provider’s compliance and ensure data segregation aligns with the customer’s due diligence obligations. Therefore, the most critical control for the Connecticut company is to establish clear policies and procedures for the use of cloud services, which encompasses monitoring and verifying the provider’s adherence to security standards.

The scenario describes a cloud service provider, “AetherCloud,” operating within Connecticut, which is subject to both US federal regulations and potentially the extraterritorial reach of EU data protection laws if it processes data of EU residents. The question probes the specific responsibilities of a cloud service provider concerning data security controls outlined in ISO/IEC 27017:2015, particularly when acting as a data processor for a customer who is a data controller. ISO/IEC 27017:2015 provides guidance on information security controls for cloud services, complementing ISO/IEC 27002. A key aspect of this standard is the shared responsibility model in cloud computing. When AetherCloud acts as a processor, its primary contractual and legal obligation is to implement and maintain the security controls that are within its purview as the cloud infrastructure and service provider. This includes controls related to the physical security of data centers, network security, access control to the cloud infrastructure, and secure configuration of the cloud environment. The standard emphasizes that the customer (data controller) is responsible for defining security requirements and managing data-specific security, while the provider is responsible for the security of the underlying cloud infrastructure and services. Therefore, AetherCloud’s direct responsibility, as per ISO/IEC 27017:2015, would be to implement controls that protect the confidentiality, integrity, and availability of the data hosted on its platform, specifically those controls that are inherent to the cloud service provision itself. This includes securing the infrastructure, managing access to the infrastructure, and ensuring the operational security of the cloud environment. The control of data encryption at rest and in transit, while crucial, is often a shared responsibility or primarily dictated by the data controller’s requirements, though the provider must support such measures. However, the most direct and foundational responsibility for the cloud provider under 27017 is the secure operation and management of the cloud infrastructure itself, which encompasses the physical and logical security of the environment where the customer’s data resides. The standard’s Annex A provides a detailed list of controls, and control A.8.1.1 “Inventory of information and other associated assets” and A.14.1.1 “Information security requirements analysis” are fundamental to understanding the scope of responsibilities. However, the question asks for the *primary* responsibility in this context. Control A.8.2.3 “Protection of information, software and information processing facilities owned by other organizations” is highly relevant, as it mandates the provider to protect assets entrusted to them. Considering the options, securing the cloud infrastructure and managing access to it are core functions of a cloud service provider that directly support the security of customer data. The specific implementation of data classification and handling policies is primarily the controller’s domain, although the provider must enable them. Therefore, the most accurate representation of AetherCloud’s primary responsibility under ISO/IEC 27017:2015, in this scenario, is to ensure the secure operation and access management of the cloud infrastructure it provides.

The scenario describes a situation where a cloud service provider, operating within the European Union and serving clients in Connecticut, is implementing controls based on ISO/IEC 27017:2015. The core of the question revolves around the provider’s responsibility for security, particularly concerning customer data. ISO/IEC 27017:2015, a code of practice for information security controls for cloud services, outlines shared responsibilities between cloud service providers (CSPs) and cloud service customers (CSCs). Specifically, it addresses controls related to the protection of information assets in cloud environments. In the context of data breaches affecting customer data stored on the CSP’s infrastructure, the standard emphasizes that the CSP is responsible for the security *of* the cloud, while the customer is responsible for security *in* the cloud. This distinction is crucial. While the CSP must implement robust security measures for its infrastructure and the services it provides, the customer is responsible for configuring those services securely, managing access, and protecting the data itself once it is within the cloud environment. Therefore, the CSP’s primary obligation regarding a breach of customer data, when the breach is attributable to the customer’s misconfiguration or inadequate access management, lies in demonstrating adherence to its own security responsibilities as defined by ISO/IEC 27017:2015, rather than directly rectifying the customer’s data loss or assuming liability for the customer’s security posture within the service. The provider’s role is to offer a secure platform and controls, which the customer must then utilize correctly. The obligation to notify relevant data protection authorities, as per GDPR, would fall primarily on the data controller (typically the customer), although the CSP might have contractual or regulatory obligations to cooperate and inform the customer.

The question probes the understanding of a specific control within ISO/IEC 27017:2015, focusing on the responsibilities of cloud service customers regarding data security. Control A.6.1.1, titled “Inventory of information and other associated assets,” mandates that the customer should maintain an inventory of information and other associated assets, including those that are processed, stored, or transmitted by the cloud service. This inventory is crucial for effective risk management and security control implementation. In the context of a Connecticut-based company utilizing cloud services, and considering the overarching principles of data governance and compliance, the customer’s responsibility extends to identifying and documenting all data assets that will reside within the cloud environment. This proactive approach ensures that the customer can apply appropriate security measures and monitor their data effectively, aligning with both ISO 27001 and the specific cloud security guidance of ISO 27017. The other options represent activities that are either primarily the responsibility of the cloud service provider (e.g., defining the security responsibilities of the cloud service provider) or are broader, less specific tasks not directly tied to the asset inventory control (e.g., establishing a data classification policy, developing a comprehensive incident response plan). While these are important security activities, they do not directly address the core requirement of Control A.6.1.1 concerning the customer’s asset inventory.