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A cloud service’s promise to store data in a chosen region does not, by itself, answer where the service processes data or who can access it. In a first-person DEV Community essay, Serguey Shinder describes a customer asking him to identify every country where its data was processed. The contract appeared to answer the question: data would be stored in the customer’s region. Shinder says a closer look revealed other paths—including telemetry, backups, support access, a newly enabled assistant feature, and an email subprocessor. His account does not identify the supplier or countries, and its details have not been independently verified.
What Shinder says the storage promise left out
Shinder recounts finding several forms of processing or access beyond the region named in the storage commitment:
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- Diagnostic telemetry: operational information generated by the service.
- Backups: copies replicated to a paired region.
- Support access: personnel working from three countries.
- A product feature: a recently enabled assistant that processed data.
- An email subprocessor: another service involved in an email-related flow.
These are examples from Shinder’s account, not established characteristics of a named provider or cloud services generally. The practical lesson is to verify each path for the specific product, configuration, and contract in use.
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Storage location is one part of a service’s processing map. A service may also generate or analyze telemetry, replicate backups, handle customer input in product features, permit support staff to access data, or disclose data to subprocessors. These activities can involve different data categories, purposes, destinations, and contractual controls. A general statement about regional storage should not be treated as a service-specific commitment about all of them.
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For procurement and compliance, it helps to separate three questions: where an operation happens, who performs or can access it, and whether the operation is an international transfer under the applicable law. Those questions overlap, but they are not interchangeable.
How the GDPR distinguishes processing abroad from a transfer
Under the European Data Protection Board’s final Guidelines 05/2021, dated 24 February 2023, processing outside the EU is not automatically a Chapter V transfer in every situation. The guidance gives examples in which a controller or processor carries out processing abroad without disclosing data to another controller or processor; those cases may fall outside the Chapter V transfer rules.
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That distinction does not make the processing exempt from GDPR responsibilities. The controller remains accountable, and processing abroad may create additional risks that need assessment. The relevant facts include which entities are involved, their roles, what is disclosed, and where processing occurs—not just the location of the storage infrastructure.
The EDPB’s Recommendations 01/2020 on supplementary measures, version 2.0 dated 18 June 2021, call for mapping destinations and onward transfers. In the recommendations’ context, remote access from a third country—including in support situations—and cloud storage outside the EEA are considered transfers. Apply that guidance to the actual entities and circumstances; it is not a universal rule for every jurisdiction or every form of access.
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Build a processing map, not a single-region answer
A useful inventory connects each data flow to its purpose, destination, participants, and controls. Shinder says he now produces a processing map for each significant service. A customer can use the same approach to make a vendor’s regional claims concrete.
| Area to map | What to record | Questions to ask |
|---|---|---|
| Data and purpose | Production records, identifiers, free-text error content, telemetry, backups, support attachments, and feature inputs; why each is used. | What data is collected or generated? Is customer content included in diagnostics? Can data be minimized or disabled? |
| Processing destinations | Primary region, backup or replica regions, telemetry and analytics destinations, feature-processing locations, and onward subprocessor locations. | Where does each category go? Are destinations different by feature, configuration, or service tier? |
| People and access | Support and staff locations, access roles, approval steps, and how ticket attachments are handled. | Can support personnel access customer data remotely? Is customer approval required, and how is access limited and recorded? |
| Changes | Notice and approval terms for new subprocessors, features, and processing locations. | How will the customer learn about a new feature or changed destination? What options exist to object, disable the feature, or end the service? |
| Contract and safeguards | Express commitments, exceptions, transfer mechanisms where required, and supplementary measures. | Do the terms cover backups and support access as well as primary storage? Which safeguards apply to each relevant transfer? |
| Evidence and configuration | Service-specific terms, provider documentation, selected settings, audit evidence, and the date the map was last checked. | Does the evidence apply to this product and configuration, or is it only a general marketing statement? |
Keep the map tied to the service actually deployed. A vendor-wide statement may not resolve the behavior of a particular feature, region, or configuration.
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Check feature releases and subprocessor changes
Shinder says an assistant feature had been enabled as part of a release in the account he describes. Treat that as an attributed example, but use it to ask a concrete change-control question: can a product update introduce a new processing path without a separate customer decision?
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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.
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Storage location does not settle foreign-authority requests
A local storage commitment does not, by itself, answer whether a foreign authority can seek access or how a provider must respond. In its final Article 48 guidance, announced on 5 June 2025, the EDPB says decisions from authorities in non-European countries are not automatically recognised or enforceable in Europe. Any response must be assessed under the applicable GDPR legal basis and transfer provisions. See the EDPB announcement on the final Article 48 guidelines.
Turn the map into a renewal and operating control
Shinder says his account’s response became a one-page processing map, refreshed annually and at renewal, together with requests for commitments on backup regions and support access. He reports that one supplier charged for those commitments and another refused; those outcomes describe his particular experience, not market-wide practice.
Use the map as a living record rather than a one-time procurement attachment. Revisit it when the service changes, a new feature is introduced, subprocessors change, or a renewal makes contract terms negotiable. If a provider cannot substantiate a material destination or access path, record the uncertainty and decide whether the risk, available safeguards, and service alternatives are acceptable.
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