PRIV- 24 – Geolocation of Data Storage and Processing

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What is this control about?

Implementing the control ‘Geolocation of Data Storage and Processing’ is crucial for ensuring the security, privacy, and compliance of an organization’s data. Geolocation control refers to the practice of strategically selecting the physical locations where data is stored and processed, taking into account factors such as data residency requirements, data sovereignty laws, and data access latency.

Available tools in the marketplace

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Available templates

TrustCloud has a curated list of templates internally or externally sourced to help you get started. Click on the link for a downloadable version:

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Control implementation

Here are some guidelines to implement a Geolocation of Data Storage and Processing:

  • Identify Data and Regulatory Requirements: Start by identifying the types of data that your organization processes and stores. Understand the specific regulatory requirements and data residency restrictions that apply to your industry and the countries where you operate.
  • Assess Data Processing Locations: Determine the geographic locations of your organization’s data processing activities, including data storage, data analytics, and data backups. Identify any potential gaps between current data processing locations and regulatory requirements.
  • Select Geolocation Options: Based on the regulatory requirements and data sensitivity, decide on the appropriate geolocation options for your data. This may involve choosing specific data centers or cloud regions that comply with the relevant regulations.
  • Engage Cloud Service Providers (CSPs): If your organization uses cloud services, engage with your cloud service providers to understand their geolocation options and data storage practices. Ensure that the CSPs comply with your organization’s data residency requirements.
  • Implement Data Replication and Backup Strategies: Consider implementing data replication and backup strategies to create redundant copies of critical data in geographically dispersed locations. This approach can enhance data availability and resilience.
  • Configure Content Delivery Networks (CDNs): If applicable, configure CDNs to optimize the delivery of content to end-users based on their geographic locations. CDNs can improve data access speed and reduce latency for users around the world.
  • Update Data Processing Agreements: Review and update data processing agreements with third-party vendors, ensuring that they adhere to the geolocation requirements and comply with applicable data protection regulations.
  • Monitor and Audit Geolocation Compliance: Regularly monitor and audit data processing activities to ensure ongoing compliance with geolocation requirements. Conduct periodic reviews to verify that data is stored and processed in the specified locations.
  • Train Employees: Provide training to employees involved in data processing and handling to ensure they understand the importance of geolocation compliance and follow the organization’s guidelines.
  • Document Geolocation Controls: Maintain comprehensive documentation of the geolocation controls and measures implemented by your organization. This documentation should include policies, procedures, technical configurations, and audit reports.

What evidence do auditors look for?

Most auditors, at a minimum, are looking for the below-suggested action:

  1. Provide the Data Residency Policy that outlines the requirements and guidelines for storing and processing data in specific geographic locations. This policy should align with relevant data protection laws and regulations.
  2. Provide the Geolocation Mapping that provides a clear mapping of data processing activities, including data storage, data analytics, and data backups, to specific geographical locations.

Evidence example

For the suggested action, an example is provided below:

PRIV 24 2

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