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ARTICLE · 27 MARCH 2026

Operational Sovereignty In Personal Data Processing In Cloud Environments

A&O Shearman
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On February 23 2026, the Spanish supervisory authority (AEPD) published an article containing recommendations on operational sovereignty when processing personal data. This follows a major incident on October 20 2025, where a cloud provider experienced technical issues in the United States which affected services globally.

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On February 23 2026, the Spanish supervisory authority (AEPD) published an article containing recommendations on operational sovereignty when processing personal data. This follows a major incident on October 20 2025, where a cloud provider experienced technical issues in the United States which affected services globally.

The AEPD highlighted that even when organisations store data in the EU, data storage may still depend on centralised services (such as identity management, DNS or encryption key management) located outside of the EEA. An issue with these services may compromise the ability to process data in the EU, including system availability and resilience, potentially resulting in a breach of Article 32 GDPR (security of processing) and impacting the rights and freedoms of data subjects.

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