Section: INFORMATION SECURITY PROGRAM MANAGEMENT
Explanation

As a subsidiary, the local entity will have to comply with the local law for data collected in the country. Senior management will be accountable for this legal compliance. The policy, being internal, cannot supersede the local law. Additionally, with local regulations differing from the country in which the organization is headquartered, it is improbable that a group wide policy will address all the local legal requirements. In case of data collected locally (and potentially transferred to a country with a different data privacy regulation), the local law applies, not the law applicable to the head office. The data privacy laws are country-specific.

Positioning security as a business enabler is the BEST way to obtain organization-wide support for an information security program, because it helps to demonstrate the value and benefits of security to the organization's strategic objectives, performance, and reputation. By aligning security with the business goals and needs, the information security manager can gain the buy-in and commitment of senior management and other stakeholders, and foster a positive security culture across the organization.
References =
CISM Review Manual, 16th Edition, ISACA, 2020, p. 37: "The information security manager should position information security as a business enabler that supports the achievement of the enterprise's business objectives and adds value to the enterprise." CISM Review Manual, 16th Edition, ISACA, 2020, p. 39: "The information security manager should communicate the value and benefits of information security to senior management and other stakeholders to obtain their support and commitment for the information security program." CISM Review Manual, 16th Edition, ISACA, 2020, p. 40: "The information security manager should promote a positive security culture within the enterprise by influencing the behavior and attitude of employees and other parties toward information security."

Section: INFORMATION SECURITY PROGRAM DEVELOPMENT