Infrastructure
Where your data sleeps
Data residency and data sovereignty are different things, and the difference usually comes down to a clause about who can be compelled to hand over a key.
A European region and a European provider are different things, and this note is about the difference.
If your data sits in a Frankfurt data centre operated by a subsidiary of a company incorporated in another jurisdiction, the physical location tells you where the disks spin. It does not tell you who can be compelled to produce their contents, or under whose law.
Residency is about geography and sovereignty is about jurisdiction. Marketing pages tend to sell the first and imply the second.
The three questions
When we audit an estate for a client who cares about this, we ask three questions and write the answers down:
- Where is the data at rest? A country, not a “region” name.
- Who is the legal entity operating the service, and where is it incorporated? The entity on the contract, rather than the brand.
- Who holds the encryption keys, and can they be compelled to use them? If the provider can decrypt your data without your involvement, they can be made to.
The third question separates a claim from an architecture. A provider who cannot read your data cannot be compelled to produce it in a readable form, which is a property of the design rather than a promise.
What we usually end up building
Dedicated or virtual machines in Sweden, Romania or Germany (the three countries we operate in), described as NixOS configurations in the client’s own repository. PostgreSQL, MinIO and Redis run by the client rather than rented as managed services, because you cannot see which jurisdiction a managed service sits under. WireGuard between regions. Backups to a second provider, in a second country, encrypted with keys the client holds.
None of this is exotic. It is roughly the architecture everybody had in 2012, with fifteen years of better tooling around it.
The part nobody puts in the brochure
In our experience it is also between forty and seventy per cent cheaper per month, but that is not why clients call. They call because a customer sent them a procurement questionnaire, or a regulator asked a question their current answer does not survive.
The saving comes from the same decision: if you are not renting managed services, you are not paying for them.
What it costs
You take on operational work you were previously buying. Somebody has to patch, monitor and be on call. For a company with any engineering capacity at all, the declarative approach makes that a smaller job than it was a decade ago, since a machine is a file and a new one is a copy of that file.
It is still not zero, and anyone who tells you it is has not run the machines.