Data Residency Lies: Why 'Processing in EU' Doesn't Mean 'Staying in EU'

“EU-only processing” sounds simple until you try to define it. Most teams discover too late that their tool was EU-friendly — not EU-restricted.

This guide is for compliance and IT folks who need a clean answer to: do our documents stay in the EU, end-to-end?

Why “EU-only” is easy to misunderstand

When people say “EU-only”, they often mix:

• Storage location: where the file sits while waiting for translation
• Processing location: where the translation actually runs
• Access + support location: where people/systems can access the job (support, logs, admin tools)

If any one of these crosses borders, you may have an international transfer problem.

If you only read one section

If you need EU-only translation servers, don’t ask “are you GDPR compliant?” Ask these instead:

1. Where are files stored?
2. Where are files processed?
3. Does anything leave the EU (logs, support tooling, backups, failover)?

If a vendor can’t answer those clearly, “EU-only” is not something they can guarantee.

What data residency means in practice (for translation)

Storage region ≠ processing region

A vendor can store files in the EU but process them elsewhere. Or process in the EU but ship logs elsewhere.

You need both.

“We use a cloud provider” is not a residency guarantee

Cloud providers have regions. Products built on top of them have architectures.

So the question is never just “is the cloud in the EU?” It’s “does this specific workflow keep my content in the EU?”

International transfers are the hard part

If personal data leaves the EU/EEA, you’ll end up in the world of transfer mechanisms and contractual safeguards. A starting point (not legal advice) is the European Commission’s overview of Standard Contractual Clauses (SCCs): EU Commission: SCCs Q&A overview

A simple “EU-only” verification checklist you can hand to procurement

Use this as your short vendor questionnaire:

1) Boundaries

• Can you guarantee EU-only storage for originals and outputs?
• Can you guarantee EU-only processing for translation jobs?
• If there is failover, does it cross regions?

2) Retention

• What is the default retention window?
• Is deletion automatic?
• Are download links time-limited?

3) Logging and support

• Do logs include document content?
• Can support access customer files?
• Is there an admin console that can “view uploads”?

4) Contracts

• Do you sign a DPA?
• Who are subprocessors, and where are they located?

For a broader vendor evaluation map (service types + red flags), start here: Which translation services should I use for sensitive documents?

Practical example: “EU-only” for a document translation workflow

An EU-only workflow usually looks like:

1. Upload to EU storage
2. Translate in EU compute
3. Download via a time-limited link
4. Auto-delete originals and outputs after a short window

If you want an explicit, end-to-end explanation of how we do this, these are the canonical references:

• How your data is handled
• GDPR & AI Act compliance

Common pitfalls (and edge cases)

Only checking the vendor’s marketing page

The marketing page will say “GDPR compliant” even when:

• storage is in the EU but logs aren’t
• EU residency is optional (opt-in)
• “EU-only” applies to one product tier, not others

Forgetting the “people” part

If support can access documents globally, the data is not practically EU-only.

Edge case: sharing download links

If you forward a download link to someone outside the EU, you may create an international transfer even if the vendor didn’t. (This is why time-limited links and controlled storage matter.)

Takeaways

Data residency is not a single checkbox. For translation tools, you need clarity on:

• storage region
• processing region
• transfer paths (logs/support/backups/failover)

Further reading

• EU Commission: SCCs Q&A overview
• GDPR overview
• How your data is handled
• GDPR & AI Act compliance
• Auto-deletion in translation tools
• HR document translation