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ACCA Strategic Professional · Strategic Business Leader · Cloud, mobile and smart technology

Brenner Logistics moves its customer database to a public cloud provider under the provider's standard contract. After a regional outage, Brenner's customers cannot access their accounts for two days, and the board asks who is accountable to customers and regulators for the personal data held. Which statement best reflects the shared responsibility position?

Brenner remains accountable for its customers' data. Using a cloud provider delegates operations, not responsibility, so Brenner must use due diligence, contractual service levels, audit rights and ongoing monitoring to manage the provider and meet its duties to customers and regulators.

  1. ABrenner remains accountable for its customers' data and must manage the provider through contract and oversightCorrect
  2. BAccountability transfers fully to the provider once the data is hosted in its data centres
  3. CAccountability is shared equally in law, so neither party is fully answerable
  4. DAccountability passes to the customers who agreed to the online terms

Explanation

Outsourcing hosting does not outsource accountability. Brenner, as data controller, must perform due diligence, set service level agreements and monitor the provider. Claiming full transfer to the provider is wrong because the legal and reputational duty to stakeholders stays with the organisation.

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