Short answer: evaluate the provider’s complete data and access system—not just the location of its VPN gateways. A tunnel can encrypt traffic between a user and a gateway, but it does not by itself prove where identity records, connection logs, telemetry, backups, support sessions, or provider-controlled data are stored and processed. Require a service-specific data-flow map, a documented transfer mechanism for each relevant jurisdiction, evidence of resource-level access controls, and assurance reports whose scope matches your planned deployment.
This approach also keeps two ideas separate. A traditional VPN primarily creates an encrypted path. Zero-trust architecture makes an explicit authentication and authorization decision before access to a particular resource, without treating a network location as inherently trustworthy. NIST’s guidance and European data-transfer authorities provide the framework; your contract, risk assessment, and applicable law determine whether a provider is acceptable.
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Start with the requirement you actually need to satisfy
“Data residency” is not a single technical promise. Your organization might require that personal data remain in a country, that regulated records stay within a region, that processing occur only in approved jurisdictions, that support personnel be unable to view content from certain countries, or that government-access risk be addressed contractually. A provider can meet one of these conditions and fail another.
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Write the requirement before comparing products. Record the jurisdictions involved, your sector, the categories of data, the people and systems that will use the service, and every contractual or regulatory restriction. Then mark which of the following each requirement covers:
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- Storage of customer content and configuration
- Processing during a live connection
- Remote administration and support access
- Identity, device, and authentication information
- Logs, telemetry, crash data, and security events
- Backups, disaster-recovery copies, and deletion
- Disclosure to subprocessors or public authorities
For European Economic Area (EEA) personal data, the European Commission describes international-transfer mechanisms rather than a universal “EU-hosted” exemption. The mechanism that fits depends on the exporter, recipient, data, destination, and circumstances. Buyers in other regions should apply the same fact-finding method to their own law and regulator guidance.
Understand what a VPN does—and does not—prove
A VPN normally encrypts traffic between an endpoint and a gateway. That protects the path from local observers and can provide controlled connectivity to private resources. It does not establish the location of every related data item. The provider may still collect account details, authentication events, device posture, connection metadata, diagnostic telemetry, support records, and billing information. Those records can be stored or accessed in different countries from the gateway through which traffic passes.
Likewise, selecting a gateway in a particular country does not necessarily mean that the provider’s control plane, logging system, backup service, or support team is in that country. Ask where each component operates and what happens when a service fails over to another region.
Use zero trust as an access model, not a product label
NIST defines zero trust as “the term for an evolving set of cybersecurity paradigms that move defenses from static, network- based perimeters to focus on users, assets, and resources.” It also states: “Zero trust assumes there is no implicit trust granted to assets or user accounts based solely on their physical or network location (i.e., local area networks versus the internet) or based on asset ownership (enterprise or personally owned).”
In practice, a provider should authenticate the user and device, evaluate context, authorize a specific resource, and enforce that decision before a session is established. Merely placing a VPN client on a zero-trust marketing page is not evidence that the service follows this model. Ask which policy engine makes the decision, which enforcement point applies it, and what is logged when the decision changes.
Map every data and access flow
Request a service-specific diagram and written description. The provider should identify the systems involved in your proposed edition, region, and support model—not a generic corporate map. For each data class, document the lifecycle below.
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Collection and transmission
List what the service collects at enrollment, sign-in, policy evaluation, connection establishment, and troubleshooting. Include usernames, directory attributes, device identifiers, IP addresses, authentication factors, posture signals, destination resources, and administrative actions. Establish whether content is inspected, whether payloads are decrypted, and which service components can see metadata.
Storage, processing, and caching
For each item, record the country or region where it is stored, the legal entity operating the system, the purpose, and the retention or deletion rule. Distinguish customer content from control-plane data. Ask whether policy decisions, certificates, keys, and session state are replicated globally, and whether a cache or analytics platform receives a copy.
Backups and disaster recovery
Identify backup locations, encryption-key locations, replication schedules, restoration operators, and deletion behavior. A “regional” primary database does not answer where immutable backups or emergency snapshots reside. Ask what happens if the selected region is unavailable and whether failover can be disabled for your tenant.
Support and privileged access
Determine where support engineers and subcontractors can connect from, what approval is required, whether access is time-limited, and whether sessions are recorded. Ask whether staff can export logs or configuration and which customer controls can block access from a disallowed country.
Subprocessors and onward disclosures
Obtain the current subprocessor list and the purpose and location of each party. Confirm how much notice you receive before a change, what objection or termination rights exist, and whether onward transfers are covered by the same legal mechanism as the initial transfer. International-transfer analysis concerns the actual recipient and arrangement, not merely a region name in a dashboard.
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For EEA personal data leaving the EEA, ask the provider to identify the transfer mechanism for every relevant entity, service component, and onward transfer. The European Commission lists adequacy decisions, standard contractual clauses (SCCs), binding corporate rules, approved certification mechanisms, codes of conduct, and limited derogations. The provider should state which mechanism applies, attach the applicable terms, and explain any supplementary safeguards.
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Adequacy decisions
An adequacy decision can permit transfers to the covered country without an additional safeguard under that mechanism. It is not a permanent warranty: the Commission can maintain, amend, or withdraw a decision. Record the decision and its scope at the time of contracting and monitor for changes.
Contractual safeguards
Check which legal entity signs the agreement, which entity acts as processor or subprocessor, and which services and data categories the clauses cover. Verify that the contract addresses security measures, assistance with data-subject rights, deletion or return, audits, and onward transfers. A clause that covers one service or affiliate may not cover another.
Authority requests and Article 48
Ask who receives government or law-enforcement demands, who assesses them, whether the provider challenges invalid or overbroad requests, and when you are notified where legally permitted. The European Data Protection Board’s final guidance on Article 48, adopted on 5 June 2025, explains that a third-country judgment or administrative decision is not automatically recognized or enforceable in Europe. A disclosure needs an applicable legal basis and transfer ground under the relevant conditions; some situations require a case-by-case assessment. Your contract should describe the provider’s process, records, and customer-notification limits rather than promising that requests can never occur.
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Test the zero-trust controls in an actual design
Use NIST SP 800-207 as the architectural baseline. Ask the provider to show how its service makes decisions before access and how it prevents a trusted network location from becoming a blanket permit.
Identity and device verification
- Which identity providers, authentication methods, and federation protocols are supported?
- How are service accounts and workload identities authenticated?
- What device-health signals are required, and how are stale or compromised credentials revoked?
- Can administrators require phishing-resistant authentication for sensitive resources?
Resource-level authorization
Require policies that name the resource, action, user or workload, and relevant conditions. A policy that allows anyone on a corporate subnet is a network rule, not proof of zero-trust authorization. For cloud-native and multi-cloud deployments, NIST SP 800-207A discusses identity-tier and network-tier policies, service identities, authentication and authorization, and enforcement points such as gateways. Ask how those elements map to your cloud accounts, private applications, and on-premises systems.
Context and continuous evaluation
NIST implementation material identifies user identity and role, device health and credentials, resource sensitivity, location, and behavior as useful policy context. Ask how often those signals are re-evaluated, what happens when a device becomes noncompliant, and whether an active session is terminated or reduced when risk changes.
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Logging and policy governance
Confirm that logs show the decision, policy version, identity, device, resource, location signal, and administrator change that affected access. Establish retention, export format, customer ownership, and access restrictions for those logs. Ask how exceptions are approved, how long they last, who reviews them, and how emergency access is recorded.
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Review assurance evidence by scope, not by logo
Request current, service-specific reports and certificates. For each artifact, record:
- The legal entity and service components assessed
- The geographic locations and environments in scope
- The assessment period and report date
- Control objectives, exclusions, and customer responsibilities
- Independent assessor or auditor
- Findings, remediation status, and any bridge letter needed for the current period
- Mapping to your obligations and internal controls
Do not treat a corporate certificate as proof that every gateway, logging service, subprocessor, or support operation is covered. If the report excludes the product edition or region you will buy, request additional evidence or document the gap.
NIST SP 1800-35, published in June 2025, documents 19 example zero-trust implementations developed with 24 collaborators. Those figures describe the guide’s cooperative work, not market adoption or measured provider effectiveness. The publication offers implementation models and mappings to common standards; it does not endorse the commercial products shown in its examples.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Build a provider scorecard
Use a weighted scorecard only after defining your non-negotiable requirements. A low price or attractive gateway map should not compensate for an unresolved transfer or authority-access issue.
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|---|---|---|
| Data location and flow | Where are content, identity data, logs, telemetry, backups, and support sessions collected, processed, stored, and deleted? | Service-specific flow diagram, location schedule, backup and deletion terms |
| Transfer and access risk | Which transfer mechanism covers each recipient and onward transfer? How are authority requests handled? | Transfer assessment, contractual clauses, subprocessor list, request procedure |
| Access architecture | Are users and devices verified before resource access? Are policies resource-specific and enforced at documented points? | Architecture description, policy examples, identity and device integration details |
| Observability and governance | What decisions and changes are logged, for how long, and with what customer access? | Sample audit events, retention settings, export and exception procedures |
| Assurance evidence | Does an independent assessment cover the exact entity, edition, region, and period? | Report or certificate, scope statement, exclusions, remediation record |
| Operational fit | Can the service integrate with your identity, endpoint, cloud, and incident-response processes? | Validated design, responsibilities matrix, incident and change procedures |
Questions to put in the procurement meeting
- “Show the countries where each category of data is collected, processed, stored, backed up, and accessed by support.”
- “Which legal entities and subprocessors handle our tenant, and how will we be notified of changes?”
- “What transfer mechanism covers each destination, including onward transfers and support access?”
- “Can you disable cross-region failover, global analytics, or support access from specified countries?”
- “What happens when your service receives a third-country judgment or administrative demand?”
- “Which identity, device, resource, location, and behavior signals can policy decisions use?”
- “Where are enforcement points located, and what happens if the control plane is unavailable?”
- “Provide the report scope, exclusions, assessment period, assessor, and customer responsibilities for the service we will deploy.”
- “How are logs exported, protected, retained, and deleted, and can our security team investigate without provider assistance?”
- “What contractual commitments apply if a region, subprocessor, transfer decision, or legal rule changes?”
Common mistakes and how to correct them
Choosing a gateway country as the residency decision
Why it fails: the gateway may be only one part of a globally operated service. Correction: require the full flow map, including control plane, logs, backups, support, and subprocessors.
Accepting “no-logs” language without definitions
Why it fails: marketing language may refer to traffic content while the service still retains identity, billing, security, or diagnostic records. Correction: ask for a field-level inventory, purpose, location, retention, and deletion evidence.
Treating a certification as universal coverage
Why it fails: an audit may cover a different entity, edition, region, or period. Correction: reconcile the report scope with your purchase order and deployment architecture.
Calling a network permit “zero trust”
Why it fails: network location alone does not provide resource-level authorization. Correction: test identity, device, resource, context, enforcement, logging, and revocation in a realistic access flow.
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Why it fails: privileged access or a government demand can expose data outside the advertised hosting region. Correction: contract for approval, notification where permitted, challenge procedures, access records, and onward-transfer controls.
A practical decision sequence
- Set the boundary: list jurisdictions, data classes, resources, users, and prohibited locations or access paths.
- Classify the data: separate content, identity and device data, telemetry, logs, backups, and support records.
- Request provider evidence: obtain the flow map, location schedule, subprocessor list, transfer terms, architecture, and assurance reports.
- Run a control test: demonstrate sign-in, device evaluation, resource authorization, policy change, revocation, logging, and incident export in a test tenant.
- Resolve legal gaps: document the transfer mechanism, authority-request process, supplementary safeguards, and contractual remedies for your jurisdictions.
- Score and approve: treat unresolved residency, transfer, or privileged-access requirements as blockers rather than averaging them away.
- Monitor after purchase: review subprocessor, region, transfer-decision, policy, and audit changes on a defined schedule and when the provider gives notice.
What a defensible approval looks like
A defensible decision file can show, for each data category, the locations and recipients, the applicable transfer safeguard, the provider’s access and deletion controls, the zero-trust policy path, and the assurance evidence that covers the exact service. It also records assumptions, exceptions, customer responsibilities, and the date on which the facts were verified.
No provider can remove your organization’s obligation to assess its own processing and transfers. Provider regions, subprocessors, audit scopes, transfer decisions, and legal requirements can change. Recheck the contract and official regulator material at procurement and during periodic review. If the decision turns on a jurisdiction-specific interpretation, involve qualified privacy or regulatory counsel rather than treating a VPN label or a regional dashboard as legal proof.
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