Your EU data is in Frankfurt. Your backups aren't.

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Your EU customer's database is in Frankfurt. Residency: done. Every night, its backups are copied to the US.

A German customer's legal team writes. Personal data stays in the EU. No transfer to the US without appropriate safeguards. So the primary database lives in Frankfurt. Backups go to us-west-2. But the user IDs are pseudonymised. Safe?

No. Backups and caches follow the same rules as the primary data. Personal data in a backup is still personal data.

And the pseudonyms? Swapping the email for an ID feels anonymous. It isn't. Pseudonymised data is still personal data. Lower risk. Same rules.

Backups aren't the only way out. Log a user's email to a global service? Now it's on US infrastructure. A US email provider receives EU personal data too. It needs a DPA. Analytics with IP addresses? IP addresses are personal data.

Residency isn't just where your database lives. It's where every copy lives. Backups, logs and caches included.

Full breakdown in the lecture.