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.

Explanation
Communicating the changes to stakeholders is the next step after updating and publishing the information security policy and standards, as it ensures that the stakeholders are aware of the new or revised requirements, expectations and responsibilities, and can provide feedback or raise concerns if needed. Communication also helps to promote the acceptance and adoption of the policy and standards, and to reinforce the security culture and awareness within the organization. (From CISM Review Manual 15th Edition) References: CISM Review Manual 15th Edition, page 183, section 4.3.3.1.

Explanation
Information owners are responsible for determining the initial recovery time objective (RTO) for their information assets and processes, as they are the ones who understand the business requirements and impact of a disruption. An external consultant may assist in conducting the business impact analysis (BIA), but does not have the authority to decide the RTO. An information security manager may provide input on the security aspects of the RTO, but does not have the business perspective to determine the RTO. A business continuity coordinator may facilitate the BIA process and ensure the alignment of the RTO with the business continuity plan, but does not have the ownership of the information assets and processes. References = CISM Review Manual 15th Edition, page 202.
When performing a business impact analysis (BIA), it is the responsibility of the business continuity coordinator to determine the initial recovery time objective (RTO). The RTO is a critical component of the BIA and should be determined in cooperation with the information owners. The RTO should reflect the maximum tolerable period of disruption (MTPD) and should be used to guide the development of the recovery strategy.