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A customer asked cloud consultant Serguey Shinder to identify every country in which their data was processed. He expected the answer to follow from the supplier’s promise to store data in the customer’s region. In his account, it did not: he says the service also involved diagnostic telemetry, backups in a paired region, support personnel in three countries, a newly enabled assistant feature, and an email subprocessor. The supplier, countries, service, and configuration are not identified, and the account has not been independently verified. The lesson is practical: a storage-region promise is not necessarily a complete map of where data is processed or who can access it.
What a regional storage promise may leave out
“Data residency” is often used in procurement to describe where customer data is kept. But a service can have other processing and access paths alongside its primary storage. In Shinder’s account, these included:
- Diagnostic telemetry, which may contain identifiers or error details.
- Backups replicated to a paired region.
- Support access by personnel working from three countries.
- A recently enabled assistant feature that handled customer input.
- An email subprocessor involved in the service.
These are examples from one unattributed service account, not a description of every cloud provider. For a particular service, the relevant locations and data flows depend on the service, configuration, contract, and subprocessors. A general statement that data is stored in a region does not establish where telemetry, backups, feature inputs, or support attachments go.
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For organisations subject to the GDPR, location is only part of the legal analysis. The European Data Protection Board’s final Guidelines 05/2021, dated 24 February 2023, distinguish processing outside the EU from a transfer under GDPR Chapter V. In some cases, processing abroad by the same controller or processor, without disclosure to another controller or processor, is not a Chapter V transfer. That does not remove the organisation’s GDPR responsibilities or the need to assess the risks of processing abroad.
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The EDPB’s Recommendations 01/2020 on supplementary measures, version 2.0 dated 18 June 2021, call for mapping transfer destinations and onward transfers. In the circumstances described in the recommendations, they treat remote access from a third country in support situations and cloud storage outside the EEA as transfers. The applicable analysis depends on the entities, data flows, and circumstances; these GDPR rules should not be treated as a universal definition for every law or every kind of access.
So asking “Where is the data stored?” is not the same as asking where it is processed, who can access it, whether it is disclosed to another entity, or whether a legally defined international transfer occurs. Those questions can overlap, but one answer does not settle the others.
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Build a processing map, not just a region field
A useful review follows the data through the service. For each activity, record the destination, purpose, data types, responsible entity, and applicable contractual or technical control.
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|---|---|
| Primary service processing | Which region handles production records? Does the answer vary by feature, configuration, or service tier? |
| Backups and replicas | Where are backup copies stored, including paired or recovery regions? How long are they retained, and do they follow a different location commitment? |
| Telemetry and diagnostics | What identifiers, logs, or error content are collected? Where are they sent, and can customer content be included? |
| Product features | Do assistants or other features process prompts, files, or other customer input? Where does that processing occur, and can the feature be disabled? |
| Support access | Where may support staff work from? Can they view customer data or ticket attachments, and can the customer approve or limit access? |
| Subprocessors and onward flows | Which entities receive or process data, for what purpose, and in which locations? How are onward transfers handled? |
Include the data category as well as the destination. Production records, account identifiers, free-text error reports, support attachments, telemetry, and feature inputs can have different sensitivity and handling. A location list without those distinctions may not show what is actually exposed or why.
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Questions to ask before choosing or renewing a service
- Which countries and regions process each category of customer data—not only the primary database?
- Where are backups and replicas held, and are those locations covered by the same contractual commitment?
- What does diagnostic telemetry contain, where does it go, and can customer content appear in it?
- Which features process customer prompts, files, or other inputs, and how are new features or changed processing locations communicated?
- From which countries can support personnel access data? Is access limited by role, time, and customer approval? How are ticket attachments handled?
- Which subprocessors handle the data, where are they located, and what notice or approval rights apply when the list changes?
- What locations and access paths are expressly covered by the contract, and what exceptions apply?
- Where GDPR Chapter V applies, what transfer mechanism and supplementary measures are documented for the actual entities and destinations?
- What evidence supports the answers: service-specific terms, current processing documentation, configuration settings, or audit evidence?
Keep the answers tied to the exact service and configuration. A broad marketing statement may not be a service-specific contractual commitment.
Account for changes and foreign authority requests
A processing map can become incomplete when a provider adds a feature, changes a subprocessor, or moves a processing activity. Shinder says an assistant feature had been enabled as part of a release in his case. Ask how such changes are announced, whether they can be declined or disabled, and what notice or approval rights the contract provides.
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- Subscription-Free Personal Cloud – Store, back up, and manage all your videos, music, and photos and access them anytime without paying any monthly fees.
- Storage Purpose-Built for Data Security – A NAS designed to keep your data safe, the LS200 features a closed system to reduce vulnerabilities from 3rd party apps and SSL encryption for secure file transfers.
- Back Up Multiple Computers & Devices – NAS Navigator management utility and PC backup software included. NAS Navigator 2 for macOS 15 and earlier. You can set up automated backups of data on your computers.
Storage location also does not, by itself, determine whether a foreign authority can make a valid request for data. In its final Article 48 guidance, announced 5 June 2025, the EDPB says decisions by authorities in non-European countries are not automatically recognised or enforceable in Europe. Any response requires a separate assessment under the applicable GDPR legal basis and transfer provisions. See the EDPB announcement of its final Article 48 guidelines.
Turn the answers into an ongoing record
Shinder says his response was to create a one-page processing map for each significant service, refresh it annually and at renewal, and seek commitments on backup regions and support access. He also says one supplier charged for a commitment and another refused; those outcomes describe his account, not a general market pattern. A current map gives procurement, security, privacy, and operations teams a shared record to check against provider terms and configuration as services change.
Quick Recap
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- Connect the LinkStation to your router and enjoy shared network storage for your devices. The NAS is compatible with Windows and macOS*, and Buffalo's US-based support is on-hand 24/7 for installation walkthroughs. *Only for macOS 15 (Sequoia) and earlier. For macOS 26, check out our LS 700 series.
- Subscription-Free Personal Cloud – Store, back up, and manage all your videos, music, and photos and access them anytime without paying any monthly fees.
- Storage Purpose-Built for Data Security – A NAS designed to keep your data safe, the LS200 features a closed system to reduce vulnerabilities from 3rd party apps and SSL encryption for secure file transfers.
- Back Up Multiple Computers & Devices – NAS Navigator management utility and PC backup software included. NAS Navigator 2 for macOS 15 and earlier. You can set up automated backups of data on your computers.
