Symptom
Telemetry routed through US regions by default
- Root cause
- SaaS vendor defaults never overridden
- Business risk
- Art. 44 GDPR transfer violation
Data Residency · GDPR
Data Residency & GDPR Engineering
Data residency and GDPR engineering is the discipline of controlling where personal data lives, who can read it, and how transfers are documented — through engineered controls, not slide-deck commitments. Evolvice implements region policies, key management, and continuous Article 30 records so GDPR holds at the infrastructure layer.
- ISO 27001
- NIS2
- BSI-Grundschutz
- GDPR
Overview
Technical Overview
GDPR compliance often breaks not in legal interpretation but in the engineering layer: telemetry leaks to non-EU regions, vendor sub-processors are unmapped, and Article 30 records drift from the actual data flow.
What we put right
- Telemetry leaking to non-EU regions via SaaS defaults
- Vendor sub-processors unmapped or undocumented
- Article 30 records drifting from the actual data flow
- Transfer Impact Assessments (TIAs) missing or outdated
Diagnostic
Common Data-Residency Failure Modes
What we encounter when reviewing data flows for German clients.
Symptom
RoPA out of date with reality
- Root cause
- Manual updates, no link to deployment pipeline
- Business risk
- Art. 30 inaccuracy
Symptom
Sub-processor list incomplete
- Root cause
- New SaaS adopted without DPO sign-off
- Business risk
- Contractual breach with customers
Symptom
Encryption keys held by SaaS vendor
- Root cause
- CMK / HYOK not enabled
- Business risk
- Schrems II exposure
Engineering
Residency is a code path, not a policy paragraph.
A residency commitment that is not enforced in code, network policy and cloud guardrails is not a control. We turn the legal commitment into deterministic engineering controls and continuous evidence.
This is what auditors increasingly expect.
Definition
Data Residency
Data residency is the engineering and policy practice of guaranteeing that defined categories of personal or regulated data are stored, processed and transmitted only within specified jurisdictions, with verifiable evidence of compliance.
Delivery model
How We Enforce EU Data Residency
Five steps from data-flow audit to enforced residency controls.
- 1
Data Flow Audit
End-to-end mapping of personal data flows, including telemetry and backup paths; sub-processor inventory.
- 2
Residency Targets
Per-data-class residency targets agreed with the DPO and product owners.
- 3
Engineering Controls
Region allow-lists, network egress filters, CMK / HYOK key management, vendor SCIM scopes.
- 4
Continuous RoPA
Article 30 records auto-generated from infrastructure metadata and reviewed quarterly.
- 5
Transfer Impact Assessment
TIA process integrated into vendor onboarding; outputs stored alongside the DPA.
Compliance
Compliance Mapping — Data Residency
How our delivery model maps to the four reference frameworks German enterprises are audited against.
| Control | ISO 27001 | NIS2 | BSI-Grundschutz | GDPR |
|---|---|---|---|---|
| Data Inventory (RoPA) | A.5.9 | Art. 21(2)(d) | CON.2 | Art. 30 |
| Encryption at Rest | A.8.24 | Art. 21(2)(h) | CON.1.A.4 | Art. 32(1)(a) |
| Region Controls | A.5.34 | Art. 21(2)(j) | OPS.2.2 | Art. 44 |
| Sub-Processor Mgmt | A.5.19 | Art. 21(2)(d) | OPS.2.3 | Art. 28 |
| Data Subject Rights | A.5.34 | — | CON.2.A.7 | Art. 12–22 |
Questions & Answers
Questions enterprise buyers ask
Definitions, delivery detail and commercial answers in one place — written to be quotable by search and AI answer engines, and readable by your team.
How it works
No. Storage in the EU is necessary but not sufficient. Schrems II requires that access by non-EU entities is also prevented through technical measures such as customer-managed keys and limited admin paths.
Working with Evolvice
Talk to the Evolvice team.
We start with a 30-minute diagnostic of your current delivery — at no cost and with no sales pitch. You leave with a written summary of findings either way.