Serving EU and UK customers from India: where your data lives matters

If you process personal data of people in the EU or the UK, GDPR's rules on international transfers apply. India doesn't have an EU or UK adequacy decision, so moving or accessing that data from India needs a transfer tool.

What customers will ask

• Which countries their data is stored in, including backups, replicas and support access.
• Which subprocessors (cloud, email, analytics, support tools) handle it, and where.
• Which transfer mechanism you use: the EU Standard Contractual Clauses, or the UK IDTA or Addendum, with a transfer risk assessment.

The hidden transfers

• Cross-region replication of storage buckets and databases.
• Backup copy rules that send snapshots to another region.
• Logs shipped to a central account in another country.
• Engineers in India accessing EU production data: access counts as a transfer too.

A practical approach

• Keep EU and UK personal data in EU or UK regions, including replicas and backups, where you can.
• Where you can't, sign the SCCs or the IDTA with the right parties and record the transfer.
• Keep a register of data stores, their countries and the transfer mechanism, and update it when infrastructure changes.

US transfers are simpler only when the recipient is certified under the EU-US Data Privacy Framework. This guide isn't legal advice.