"Protect your data from external interference: controlled physical residency, managed third-party access, effective audit rights, genuine portability."
Critical data mapping, operational classification, residency and localization, Data Act & portability, cross-border data flow auditing.
GDPR Art. 44-49, Data Act 2025, BCBS 239, DORA Art. 28, Cloud Act vs GDPR, Schrems II, PSD3.
CDO, DPO, CISO, Data Owners, IT legal counsel, compliance teams, data architects.
Half day (3h30) — 2 theoretical sessions + 1 mapping workshop.
Every sovereignty framework starts with knowing which data deserves what level of protection. Classification must be actionable, not academic.
Physical datacenter, country, applicable jurisdiction. A contract stating "EU" does not guarantee the absence of metadata transfers.
Government access clauses (US Cloud Act, UK CLOUD Act). Mandatory vendor access audit trail (DORA Art. 28.3.e).
Fine-tuning and RAG via external API = potential transfer. EU AI Act requires training data traceability for high-risk systems.
Data Act Art. 23-35: right to portability of data generated by digital services. 30-day deadline, interoperable format, no excessive fees.
Certified destruction clause (GDPR Art. 28.3.g). Residual technical retention by the vendor = regulatory and competitive risk.
Any cloud contract that fails to answer these 5 questions exposes the organization to a latent GDPR violation and a DORA risk to business continuity.
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