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Start with the controls you actually need
Enterprise AI due diligence has three separate questions:
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- Assurance: Has an independent assessor examined the exact service boundary, during a stated period, against a named standard?
- Location: In which countries are customer content, model execution, routing, logs, account data and support operations handled?
- Accountability: Which protections are contractual provider commitments, and which controls must your organization configure or operate?
A vendor can have an impressive portfolio and still be unsuitable for a workload if the relevant model endpoint is outside the certificate scope, inference is unavailable in your required region, or support staff and subprocessors can access data from another jurisdiction.
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Use the product-level evidence below as a purchasing baseline. Treat every statement as applying only to the named edition, feature, region and date.
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What SOC 2 and ISO certifications tell you
SOC 2 Type 2
A SOC 2 Type 2 report describes controls tested over a defined examination period against selected Trust Services Criteria. Ask for the complete report under appropriate confidentiality terms, not a badge or a one-page summary. Record:
- the examination period and report date;
- the Trust Services Criteria included;
- exceptions or control deviations and management’s response;
- complementary user-entity controls that your organization must perform; and
- the precise services, environments and legal entities inside the service boundary.
OpenAI states that it has undergone a SOC 2 Type 2 examination. That statement does not, by itself, establish that every OpenAI product, model, region, support workflow or customer configuration is inside the same boundary.
ISO/IEC 27001:2022
ISO/IEC 27001 certification is evidence that an information-security management system (ISMS) met the auditor’s requirements within a documented scope. Check the certificate’s issuing body, validity dates and scope wording. A certificate may cover a corporate ISMS or selected services rather than every AI product.
OpenAI’s 2026 documentation identifies an ISO/IEC 27001:2022 certification for specified API and ChatGPT business services. Obtain the certificate and scope statement to determine whether the service and deployment you plan to use are included.
ISO/IEC 27701:2019
ISO/IEC 27701:2019 extends security-management practices into privacy-information management. It can support confidence in privacy governance, but it does not replace a data-processing agreement (DPA), a controller/processor analysis, or a process for data-subject rights.
OpenAI’s 2026 documentation identifies ISO/IEC 27701:2019 certification for specified business services. Confirm the applicable privacy roles, processing purposes, retention terms and rights process in the contract.
ISO/IEC 42001:2023
ISO/IEC 42001:2023 concerns an AI management system: governance, risk processes and organizational controls for developing or using AI. It is not a certificate that a particular model’s answers are accurate, safe for every use case or legally compliant in every country.
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OpenAI’s 2026 documentation identifies ISO/IEC 42001:2023 coverage for its AI management system. Require separate evidence for model evaluation, human oversight, prohibited-use controls, incident handling and the deployment configuration you will operate.
Other frameworks need the same precision
Azure publishes a broad portfolio that includes SOC 2, ISO 27001, ISO 27017, ISO 27018, ISO 27701, CSA STAR, GDPR guidance, FedRAMP and regional programs. The portfolio is useful for finding candidate services, not for proving that a chosen model endpoint is compliant. Match each claim to the service, region, workload, edition and customer responsibilities. Apply the same discipline to HIPAA/HITRUST, PCI DSS and any national or sectoral program.
| Evidence | What it can establish | What you still must verify |
|---|---|---|
| SOC 2 Type 2 report | Controls operated and were tested during a stated period. | Trust criteria, exceptions, complementary user controls and exact service boundary. |
| ISO/IEC 27001:2022 certificate | An ISMS met the standard within the certificate scope and validity. | Whether your product, region, legal entity and processing activities are inside that scope. |
| ISO/IEC 27701:2019 certificate | Privacy-management controls are part of a certified management system. | Controller/processor terms, retention, transfers and data-subject rights execution. |
| ISO/IEC 42001:2023 certificate | An AI management system has been assessed against the standard. | Model behavior, output quality, use-case restrictions and deployment-specific safeguards. |
| CSA STAR, FedRAMP, HIPAA/HITRUST or PCI DSS reference | Potential alignment with a sector or government framework. | Exact authorization or attestation, service and region, workload eligibility and your configuration duties. |
Data residency is not inference residency
Storage residency
Storage residency specifies where in-scope customer content is stored at rest. OpenAI defines ChatGPT data residency as allowing customers to keep in-scope customer content stored at rest in a selected geographic region. Eligible ChatGPT customers can select Australia, Canada, or Europe (the European Economic Area plus Switzerland) for this at-rest setting.
For the API, residency is configured per project and applies to customer content handled by supported endpoints. OpenAI states that data-residency controls are a project configuration option defining the location of infrastructure used to provide services. A project setting is therefore not a blanket account-wide guarantee.
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Inference residency concerns the location of GPU execution for a request. It is a separate control from where prompts, uploaded files or outputs are stored. OpenAI offers inference residency only to eligible customers and for supported workloads and regions. A region may support storage residency without offering regional inference.
OpenAI explicitly states: “Does inference residency guarantee that all processing stays in-region? No.” GPU execution can be local while another operation, such as routing, authentication, abuse monitoring or transient processing, occurs elsewhere. Obtain the provider’s regional-processing matrix for each endpoint and feature you plan to enable.
System data and transient processing
OpenAI’s API documentation states: “Data residency does not apply to system data.” System data can include service and account metadata rather than the customer content covered by a residency setting. OpenAI’s ChatGPT documentation also notes that workspace metadata, billing information, user logins and transient processing may be outside the selected region.
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Ask the vendor to classify every data type separately:
- prompts, uploaded files, embeddings and generated outputs;
- account, workspace and billing records;
- authentication data, routing information and telemetry;
- security, abuse-monitoring and trust-and-safety records;
- application, diagnostic and audit logs; and
- support tickets, recordings and material accessed during troubleshooting.
Document the retention period, storage country, access roles and transfer mechanism for each class. Never infer local handling for one class from a statement about another.
Compare the four common hosting architectures
“Cloud AI” is not one control model. Compare the architecture that will process each workload.
| Architecture | Typical strengths | Questions and trade-offs |
|---|---|---|
| Provider-managed SaaS | Fastest deployment, integrated identity and collaboration features, and a provider-operated security stack. | Workspace metadata, support access, feature availability and regional exceptions may be outside your selected content region. Customer control over network paths and keys can be limited. |
| Regional API project | Programmatic control over projects, endpoints, retention settings and application-level routing; residency can be configured per project where supported. | Regional processing may differ by endpoint. System data is excluded from the residency setting, and your application, logs and credentials remain your responsibility. |
| Hyperscaler-hosted model | May integrate with an existing cloud region, private networking, customer-managed keys, dedicated capacity and established procurement controls. | Certification and residency claims attach to the particular cloud service and model deployment, not automatically to every model or feature in the platform. Shared responsibility is complex. |
| Self-hosted or dedicated deployment | Maximum control over network boundaries, execution location, keys, logging and operator access. | You assume infrastructure security, patching, model updates, capacity planning, monitoring, incident response and much of the compliance evidence. |
Score each option against the same control surface:
- Storage-at-rest country or region.
- GPU inference country or region.
- Routing, load balancing and TLS-termination locations.
- System metadata, diagnostics and log locations.
- Subprocessors and support-access countries.
- Customer-managed keys or external key management (EKM).
- Retention, deletion and zero-data-retention eligibility.
- Private networking, isolation and dedicated-capacity options.
- Features or endpoints excluded in each region.
Jurisdiction is a supply-chain question
Data can cross a border through a contracting entity, a cloud subprocessor, a support engineer, a monitoring system or a legal request even when primary storage is regional. Perform the following review before approving a vendor.
1. Identify the contracting structure
Record the legal entity signing your agreement, its incorporation country, governing law, venue and the entity responsible for service delivery. Confirm whether a local sales subsidiary is merely a reseller while another entity remains the processor.
2. Map subprocessors and access paths
Obtain the current subprocessor register and record each entity’s country, purpose, product, data access and notification process. OpenAI’s register, updated October 14, 2026, lists entities such as Cloudflare, Microsoft and Google Cloud Platform for particular products and purposes. Presence on a register does not prove that an entity can access your content; ask what technical and contractual path exists and whether access is limited to metadata or includes customer content.
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3. Separate content from operational data
Put prompts and files on one data-flow diagram and account data, billing, telemetry, logs, abuse-monitoring records and support material on separate lanes. Apply a destination prohibition and retention limit to each lane rather than to “data” as one undifferentiated category.
4. Confirm transfer and government-access terms
Ask which international-transfer mechanism applies, where onward transfers can occur, how supplementary measures are implemented and how the provider handles government demands. Obtain incident-notification deadlines, cooperation duties and your rights to challenge or receive notice of a request where legally permitted.
5. Test human access
Get written answers on whether support, trust-and-safety review, abuse monitoring or model-improvement operations can access content; under what trigger; from which countries; with what approval, logging and retention; and whether your plan can opt out.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.A practical five-stage buying sequence
Stage 1: Classify the data
Mark each proposed use as public, confidential, personal, health, financial, export-controlled or otherwise regulated. Set prohibited destinations, maximum retention, deletion deadlines and whether de-identification or redaction is mandatory. Decide which categories are prohibited from a pilot.
Stage 2: Write mandatory controls
Turn the classification into contract and architecture requirements:
- certificate and report scope, validity and examination period;
- DPA roles, purposes, deletion and data-subject rights;
- encryption in transit and at rest, key ownership and EKM support;
- storage and inference regions, routing and transient-processing locations;
- private connectivity, dedicated capacity and tenant isolation;
- zero-data-retention eligibility and log controls;
- incident notification, audit cooperation and subprocessor notice; and
- governing law, transfer mechanism and government-request procedures.
Stage 3: Compare architectures
Score provider SaaS, a regional API project, a hyperscaler deployment and self-hosted or dedicated capacity against the nine control axes above. Mark “not available,” “not stated” or “customer responsibility” explicitly; do not treat an unanswered question as a pass.
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Stage 4: Verify evidence
Review the actual SOC report or ISO certificate, not a marketing badge. Compare its service boundary with the data-flow diagram and contract. Record feature-level regional exclusions, endpoint limitations and any requirement that you configure a setting yourself.
Stage 5: Pilot safely
Use synthetic or redacted data. Test retention, deletion, export, audit logging, key rotation, support escalation and account termination. Inspect network paths and logs, confirm which staff roles can see content, and obtain written answers for unresolved jurisdiction questions before production data is introduced.
Evidence to request in the procurement file
- Current SOC 2 Type 2 report, including period, criteria, exceptions and complementary user-entity controls.
- Current ISO certificates, issuing body, validity dates and scope statements for ISO/IEC 27001:2022, ISO/IEC 27701:2019 or ISO/IEC 42001:2023 where claimed.
- DPA, standard contractual clauses or other transfer mechanism, retention schedule and deletion procedure.
- Subprocessor register with entity, country, purpose, access type and change-notification terms.
- Written regional-processing matrix covering storage, inference, routing, TLS termination, metadata, logs, support and transient processing.
- Encryption architecture, key-management choices, EKM or customer-managed-key documentation and key-access audit records.
- Private-networking, dedicated-capacity and tenant-isolation descriptions for the selected plan.
- Incident response commitments, notification clocks, audit rights and government-request procedures.
- Feature and endpoint exclusions for every region you may use.
Common purchasing mistakes and fixes
Mistake: treating a badge as universal compliance
Fix: tie every certification to the product, region, legal entity, version and audit period; retain the scope statement and report.
Mistake: equating regional storage with local processing
Fix: require separate answers for storage, inference, routing, metadata, logs, support and transient operations.
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Fix: map every processor’s country, purpose and access path, then review transfer and notice terms.
Mistake: assuming the provider owns every control
Fix: list customer tasks for identity, project configuration, network restrictions, key management, logging, retention and deletion testing.
Mistake: piloting with production records
Fix: use synthetic or redacted data until regional behavior, retention and human-access questions are documented.
How to make the final decision
Approve a service only when the evidence matches the workload’s strictest requirement. A provider-managed service is often suitable for public or low-sensitivity work when its boundary and support practices are acceptable. A regional API or hyperscaler deployment can add project-level location, network and key controls, but only where the required endpoint supports them. Dedicated or self-hosted capacity is justified when execution location, operator access or isolation cannot be contractually and technically demonstrated otherwise.
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Record the decision as a workload-specific statement: data classes, allowed countries, storage region, inference region, excluded features, subprocessors, retention, keys, network path, contractual entity and customer controls. Revalidate it when the model, endpoint, region, subprocessor list or certificate scope changes.
Quick Recap
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