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Start with a workload inventory
Assess each workload separately. A move that suits one application may be unsuitable for another because of different data, dependencies, latency needs, or recovery requirements.
Record what runs and what it depends on
- List servers, applications, databases, storage, integrations, network services, identity services, and business owners.
- Document data classification and sensitivity, volume and expected growth, software and hardware dependencies, licensing, resource utilization, peak and seasonal demand, response-time requirements, and maintenance windows.
- Map upstream and downstream services, external APIs, and other integrations. Record the order in which components must move so a migration does not break a dependency.
For each workload, decide whether to move it unchanged, modify or re-platform it, leave it where it is, or replace it. South African Reserve Bank guidance for banks specifically recommends asset registers, data classification, interdependency analysis, readiness assessment, and review of gaps and integration requirements. That is useful context for a bank’s assessment, not a universal legal opinion for every organization.
Find out where the data and access will be
Whether data must stay in South Africa depends on the data, organization, applicable law, sector rules, public-sector obligations, and contracts. Do not infer a universal private-sector residency rule from the fact that a facility is in South Africa.
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Map more than the production copy
Ask the provider to identify the locations of production data, replicas, backups, logs, and management systems. Also ask where support staff and administrators can access data, and where support and management-plane access takes place. Include any cross-border transfers in the assessment. Request specific location commitments and advance notice of location changes rather than relying on a general “local hosting” assurance.
Identify whether the workload includes personal information, financial or health records, government information, Critical Information Infrastructure, or sector-regulated data. Have your legal or compliance owner check the current POPIA transfer conditions, relevant sector requirements, government rules, and contract terms against the actual data flows and organization.
Put the 2021 government statement in context
In a speech on 18 June 2021, then Minister of Communications and Digital Technologies Stella Ndabeni-Abrahams said that Critical Information Infrastructure data should be stored within South Africa’s borders. In the next sentence, she said: “Kindly also note that there is no intention to force the private sector to store their data in the High-Performance Computing Data Processing Centre.” The first statement concerned Critical Information Infrastructure; neither sentence establishes a blanket residency rule for every private business today.
The South African Government’s National Data and Cloud Policy is dated 31 May 2024. Check its text alongside applicable legislation and current sector rules; the minister’s 2021 speech is not a substitute for that review. SARB G5/2018 is relevant to banks. It calls for banks to consider classification, data locations, security, third parties, and the cloud model, but should not be treated as general legal advice for other organizations.
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Assess the facility, provider, and division of responsibility
Choosing a data center also means evaluating the provider’s operating model and the risks in its contract. Verify the exact primary and recovery-site locations, not just the provider’s general service footprint.
Request evidence about the site and its controls
- Review physical access controls, power and cooling arrangements, environmental and geographic risks, and the provider’s plans for capacity and maintenance.
- Request current certifications and assurance reports, including their scope. A certificate name alone does not show which site, services, or controls were assessed.
- Ask how monitoring, patching, vulnerability management, privileged access, incident response, and support escalation work. Confirm support coverage and maintenance-notice practices.
- Identify subcontractors and the services they perform. Ask how their controls and access are managed.
Make accountability testable
Write down who performs each security, migration, and continuity task: your team, the provider, or another party. Agree on incident notification, the evidence you can receive, audit access, service-level measurement, and remedies if commitments are missed. Public procurement specifications ask providers to disclose data location, certifications, and security attestations; banking guidance similarly calls for due diligence proportionate to data criticality, third-party assurance, security requirements, and explicit continuity responsibilities.
Prove connectivity and workload performance
Performance depends on the workload and the network route it actually uses. A facility’s general capabilities do not establish that your application will meet its response-time or throughput needs there.
Map the routes and measure the baseline
- Document network paths, bandwidth, latency, DNS, IP addressing, routing, firewalls, VPN or private connectivity, identity integration, external APIs, and other system connections.
- Measure current resource use, traffic, storage needs, and application response. Test representative loads against the destination’s CPU, memory, storage throughput and IOPS, and network capacity.
- Include peak and seasonal demand, expected growth, and the time needed to transfer the initial data set. Confirm that the planned migration window is realistic for the data volume and available bandwidth.
Check dedicated connectivity only where the design needs it
For a hybrid or cloud-integrated design, establish whether a dedicated link to the named hyperscaler is available, its capacity and resilience, who operates it, and how it fails over. Dedicated hyperscaler connectivity was required for integration or data transfer in an Auditor-General South Africa (AGSA) IaaS procurement clarification; that procurement example does not make such a link necessary for every migration.
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Set security, backup, and recovery requirements
Define controls and recovery targets per workload, based on business impact. Confirm which obligations the provider accepts in writing and which remain with your organization.
Agree security and backup controls
- Specify encryption in transit and at rest, key custody and recovery, identity integration, least privilege, administrator MFA, logging, monitoring, vulnerability management, and network segmentation.
- Agree how and when the provider must notify you of an incident, who leads response, and how evidence is made available.
- Protect backups from production credentials and routine deletion paths. Set retention, immutability, restore priority, and authority to initiate recovery.
- Check that backup and replica locations, as well as access to them, meet the requirements established for the data.
Set workload-level RTO and RPO
Recovery time objective (RTO) is the time allowed to restore a workload after disruption; recovery point objective (RPO) is the maximum acceptable gap in recovered data. Set both through a business-impact analysis for each workload, then agree which parts of each target the provider must meet. Define failure triggers, communications, decision authority, recovery roles, failback, and an alternative plan if the provider is unavailable.
Procurement documents provide examples, not national benchmarks or universal legal requirements:
| Procurement example | Specified requirement | How to interpret it |
|---|---|---|
| National Lotteries Commission, NLC2026-002 (2026) | For business-critical workloads, RTO of 1–3 hours and RPO of 15 minutes–1 hour; failover tests twice yearly and backup/restoration tests quarterly. | These are assumptions and testing frequencies in that procurement. The document lists less stringent ranges for other workload classes; do not apply the business-critical figures to every workload. |
| AGSA13/2023 (2023) | At least 100 km between the DR site and primary data center. | This was an AGSA procurement requirement, not a statutory minimum for South African data centers. |
Test recovery, not just backup-job status
Schedule migration rehearsals, isolated restores, disaster-recovery simulations, failover, and failback. Verify that the restored data is readable and intact and that the application works—not merely that backup jobs report success. AGSA procurement material calls for simulated DR testing without production impact and two formal tests per year. An NLC procurement document calls for twice-yearly failover tests and quarterly backup/restoration tests. Those frequencies belong to the respective procurements, not to a general national rule.
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Plan migration, rollback, and exit
Agree the sequence and decision points before cutover. A migration plan should identify owners, dependencies, maintenance windows, communications, validation steps, and the conditions for proceeding, rolling back, or rescheduling.
Rehearse the move and its recovery paths
- Run a representative rehearsal and confirm that data transfer, application dependencies, connectivity, and validation steps work as planned.
- Set cutover criteria, including who approves the move and how application and data integrity will be checked before users rely on the destination.
- Document rollback steps, decision authority, and how the original environment will remain available until the destination is accepted.
- Exercise restore, failover, and failback procedures so the teams responsible can carry them out and verify the recovered service.
Keep data portable and define termination terms
Specify data ownership and rights, export formats, documentation, access to logs and audit evidence, transition support, costs, and time limits. Contract for data return or transfer at termination, verified deletion, and evidence of deletion. Keep documented steps and named responsibilities for resuming service in-house or moving to another provider.
Confirm that data can be exported in a usable, readable form and restored without an integration that will disappear when the contract ends. Test export and import or recovery portability before the migration is complete. SARB guidance for banks emphasizes retaining usable, readable, portable data and planning the hardware, software, and procedures needed to change providers or return in-house.
Use a decision record before approving the move
For each workload, retain the evidence and decisions that support approval. A concise record should show:
- the workload owner, dependencies, classification, expected growth, performance needs, and chosen migration approach;
- the applicable legal, sector, public-sector, and contractual requirements, plus the locations of data, replicas, backups, logs, and support access;
- the destination site and provider evidence reviewed, control responsibilities, audit rights, incident commitments, and service remedies;
- measured performance and connectivity results, workload-level RTO/RPO, tested restore and failover arrangements, and rollback criteria; and
- the agreed data-return, portability, deletion, and transition provisions.
Compare candidate facilities or providers using those workload-specific findings: compatibility and measured performance, data and access locations, regulatory fit, security evidence, recovery tests, connectivity, costs, scalability, interoperability, responsibility boundaries, and exit options. The title alone cannot determine which provider or hosting model is suitable.
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