Checklist
The data residency evidence pack
The five attachments that answer most data-location questions in a security questionnaire, and how to keep them true every quarter.
"Our data stays in the EU" is a promise. A customer's data protection officer wants a control and a report. I'm starting to see the same data-location questions in a lot of security questionnaires. These five attachments answer them. They live in one dated folder, with a refresh every quarter.
From the talk: Leaving us-east-1: moving a startup into the EU without downtime
The five attachments
Each yes scores one point.
- 1.A data map. Every data store with its region and the encryption key that protects it.
- 2.The region policy, with proof that it works. The service control policy that denies other regions, plus a screenshot of a denied call to a non-EU region.
- 3.A sub-processor list with locations. Every provider that touches customer data, what it does, and where.
- 4.A report of resources outside the approved regions. From an AWS Config aggregator or Resource Explorer. The right answer is a short list of global services, and nothing else.
- 5.A record of what still leaves the EU. Account metadata, billing, identity configuration, and some service logs sit in US regions whatever happens. Each one goes on the list as a transfer, with its legal basis.
Residency or sovereignty
I see residency in a lot of contracts: where the bytes sit. Some contracts ask for sovereignty instead: operational independence from a US parent company. Keeping data in Frankfurt doesn't make it immune to US law when the provider is a US company. When a contract asks for sovereignty, I'd start with customer-held keys. The AWS European Sovereign Cloud and EU providers come next, and each one has a cost.
The legal basis for what still leaves
Transfers to the US rest on the EU-US Data Privacy Framework (Commission Implementing Decision (EU) 2023/1795) and standard contractual clauses, under Chapter V of the GDPR (art. 44 to 46 Regulation (EU) 2016/679). The General Court upheld the framework on 3 September 2025 (Case T-553/23). An appeal is pending at the Court of Justice (Case C-703/25 P). A written list of what still flows to the US turns an adverse ruling into a known list instead of a surprise.
Every quarter
- We re-run the report of resources outside the approved regions.
- We repeat the denied cross-region call and replace the screenshot.
- We update the sub-processor list and the date on the data map.
What I leave out on purpose
I leave out a move to a sovereign cloud or a second provider just because it sounds safer. That move costs real money and time. I make it when a contract asks for it, not before.
Next step
I highly recommend bringing the data-location question from your last security questionnaire to a thirty-minute call. We'll mark what already has proof and what's still sitting in Virginia. What did your last answer to that question say?
Book a callThese takeaways are an engineer's reading of the rules and the tools. I wrote them to help teams decide what to build. They aren't legal advice. I recommend checking the current text with your own counsel before planning around a date or a threshold.
How I help
Cloud migration
I move teams onto AWS, Azure, or Google Cloud, or out of a setup they've outgrown. I map every dependency before anything moves.
Cloud security hardening
I find the gaps in your cloud accounts, identity, network, and data, rank them by what an attacker reaches first, and close them with your team.
Other takeaways from this talk
Template
Migration readiness map
A one-page map of every workload and data store before a move to an EU region, plus a Terraform policy that denies non-EU regions.
Runbook template
Cutover runbook
A one-page cutover runbook for moving data to an EU region: the countdown, go and no-go criteria, and a rollback with an owner per line.
Checklist
Old-region decommissioning checklist
What to find and delete in the old AWS region after a move to the EU: snapshots, vaults, log buckets, images, secrets, and the test stack.
Let's talk.
A 30-minute call, no pitch. We look at your current setup, your stage, and the thing that's bothering you about it. I give a straight opinion on what to change, what to leave alone, and whether the problem is the one it looks like. What's the one thing in your stack you'd fix tomorrow?
Prefer email or phone? hello@netninjas.eu or +31 6 45984313