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HCISPP · Question #37

An international medical organization with headquarters in the United States (US) and branches in France wants to test a drug in both countries. What is the organization allowed to do with the test…

The correct answer is C. Share it with a third party. Sharing test subject data with a third party (C) is permissible in international clinical research, provided proper consent and data-sharing agreements are in place - this is standard practice for sharing with regulatory bodies (like the FDA or EMA), ethics committees, or…

Regulatory and Standards Environment

Question

An international medical organization with headquarters in the United States (US) and branches in France wants to test a drug in both countries. What is the organization allowed to do with the test subject's data?

Options

  • AAggregate it into one database in the US
  • BProcess it in the US, but store the information in France
  • CShare it with a third party
  • DAnonymize it and process it in the US

How the community answered

(57 responses)
  • A
    5% (3)
  • B
    2% (1)
  • C
    84% (48)
  • D
    9% (5)

Explanation

Sharing test subject data with a third party (C) is permissible in international clinical research, provided proper consent and data-sharing agreements are in place - this is standard practice for sharing with regulatory bodies (like the FDA or EMA), ethics committees, or contract research organizations (CROs) overseeing trial integrity.

Why the distractors fail:

  • A is wrong because France is an EU member state, meaning participant data is subject to GDPR; simply aggregating French participants' identifiable data into a US database violates GDPR's cross-border transfer restrictions.
  • B is wrong because processing EU health data in the US - even with storage in France - still triggers GDPR's data transfer rules, which require more than just keeping a copy in the EU.
  • D is wrong because clinical trial data must often remain identifiable for safety follow-up and regulatory inspection; true anonymization is extremely difficult to achieve under GDPR's strict standard, and anonymized data cannot support patient-level safety monitoring.

Memory tip: In international drug trials, data flows - to regulators, ethics boards, and sponsors - but it cannot freely leave the EU without protections. Think: "Share with oversight = OK; ship to the US = GDPR problem."

Topics

#GDPR Data Transfer#Clinical Trial Data#Third-Party Processing#Healthcare Authorization

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