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Difficulty: Very hardData Governance, Classification, and Privacy Controls

A healthcare organization is deploying an automated diagnostic analytics platform in a public cloud environment to analyze patient telemetry data alongside medical records. To comply with strict regulatory privacy requirements and organizational risk policies, the Chief Information Security Officer (CISO) mandates that: (1) any data exported to the cloud platform must be mathematically non-reversible to prevent individual identity restoration, and (2) governance structures must maintain a clear separation between business accountability for data and technical infrastructure security implementation. Which of the following controls and governance practices should the organization implement to satisfy these mandates? (Select TWO.)

  1. Implement data anonymization techniques such as k-anonymity and noise addition to render patient identifiers irreversibly detached from telemetry records before cloud export.Answer
  2. B
    Utilize data tokenization backed by an on-premises token vault mapping service to achieve permanent, non-reversible data sanitization prior to cloud ingestion.
  3. Designate clinical department leaders as data owners to define classification levels and usage restrictions, while assigning IT systems administrators as data custodians to configure storage permissions and encryption controls.Answer
  4. D
    Assign IT infrastructure engineers as data owners responsible for determining privacy policy compliance thresholds, while requiring clinical department heads to configure access control lists on database servers.

Answer

The organization should implement data anonymization (such as k-anonymity and noise addition) to ensure patient identifiers cannot be reversed, and designate clinical department leaders as data owners while assigning IT administrators as data custodians to maintain separation between business accountability and technical execution.
Data anonymization (e.g., k-anonymity, differential privacy, differential noise addition) irreversibly breaks the link between PII/PHI data subjects and the dataset, satisfying the mandate for non-reversible export. Concurrently, assigning business unit leaders as Data Owners establishes policy accountability while appointing IT administrators as Data Custodians ensures technical control enforcement without blurring role boundaries.

Step-by-Step Solution

1
Analyze Privacy Technical Control Requirement (Irreversibility)
Evaluate privacy-enhancing technologies (anonymization vs. tokenization/pseudonymization) for mathematical non-reversibility.
Anonymization removes or distorts identifying data so that re-identification is impossible (non-reversible). Tokenization retains a reverse mapping in a vault, making it a reversible technique.
2
Analyze Governance Role Separation Requirement
Determine the proper allocation of duties between Data Owner and Data Custodian.
Data Owners are business executives accountable for data classification, retention, and policy. Data Custodians are technical personnel responsible for implementing security controls, backups, and access permissions defined by the owner.
3
Synthesize Correct Selections
Select anonymization for technical privacy compliance and the owner/custodian alignment for governance compliance.
Combining anonymization with proper data owner and custodian role delegation satisfies both CISO mandates.

Key Concept

Privacy-Enhancing Technologies (Anonymization vs. Tokenization) and Governance Role Segregation (Data Owner vs. Data Custodian)
Estimated Time:2m 30s
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Topics

Data Governance, Classification, and Privacy Controls

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