Reference / A to Z

Residency and transfer glossary

The vocabulary of AI data residency in one place, from Chapter V and adequacy to Rego, Merkle inclusion proofs and zero data retention. Every term has a link you can paste into a review comment.

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Adequacy decision
Air-gapped deployment
Annex IV technical documentation
Anonymization
Article 28 processor terms
Article 30 records of processing (RoPA)

58: terms defined for DPOs, counsel and AI platform engineers
19: letters in the jump bar, each with a stable anchor you can link to
156: cross-references between related terms, so one lookup leads to the next
20: regulatory guides that use these terms in context, with citations

Terms

A8

Adequacy decision: A decision by the European Commission under GDPR Article 45 that a third country, territory or sector ensures a level of data protection essentially equivalent to the EU's. Personal data can then flow there without a further transfer tool. Current decisions include the United Kingdom, Switzerland, Japan, the Republic of Korea and, for certified organisations only, the United States under the Data Privacy Framework. The Commission reviews each decision periodically and can suspend or amend it.; See alsoChapter V (GDPR)Data Privacy Framework (DPF)Article 46 standard contractual clauses (SCCs)
Air-gapped deployment: An installation with no network path to the vendor or the public internet. Licences are validated offline, software updates arrive as signed bundles that the customer transfers and verifies, and no telemetry leaves the site. YTT Secunet offers this on Sovereign Dedicated for defence suppliers, government and banks, with receipt signing keys generated and held in the customer's own HSM so that no YTT Secunet system can sign on the customer's behalf.; See alsoHardware security module (HSM)Control plane Sovereign cloud
Annex IV technical documentation: The technical documentation that providers of high-risk AI systems must draw up under Article 11 of the EU AI Act, with contents listed in Annex IV. It covers a general description of the system, its development process, data and data governance, monitoring and control, the risk management system, changes over the lifecycle, standards applied, the EU declaration of conformity and the post-market monitoring plan. It must exist before the system is placed on the market and be kept current.; See alsoHigh-risk AI system Fundamental rights impact assessment (FRIA)General-purpose AI (GPAI) model
Anonymization: Processing that makes it impossible to identify a person by any means reasonably likely to be used, taking into account cost, time and available technology (GDPR Recital 26). Truly anonymous data falls outside the GDPR. The bar is high: removing names is rarely enough, because free text such as an AI prompt often identifies someone through context. Most masking applied to prompts in practice is pseudonymization, not anonymization.; See alsoPseudonymization Tokenization vault
Article 28 processor terms: The contract terms GDPR Article 28(3) requires between a controller and a processor. They set the subject matter, duration, nature and purpose of processing, the types of data and data subjects, and oblige the processor to act only on documented instructions, including on transfers to third countries. They also cover confidentiality, Article 32 security, conditions for engaging subprocessors, assistance to the controller, deletion or return of data at the end, and audits.; See alsoController Processor Subprocessor
Article 30 records of processing (RoPA): The written record of processing activities that controllers and processors must keep under GDPR Article 30 and show to a supervisory authority on request. A controller's record lists purposes, categories of data subjects and data, recipients, transfers to third countries with the safeguards used, retention periods and a general description of security measures. An AI feature that sends prompts to a model provider needs its own entry, including where inference runs.; See alsoController DPIA (data protection impact assessment)Chapter V (GDPR)
Article 46 standard contractual clauses (SCCs): Model transfer clauses adopted by the European Commission as an appropriate safeguard under GDPR Article 46(2)(c). The current set, Commission Implementing Decision (EU) 2021/914 of 4 June 2021, is modular: controller to controller, controller to processor, processor to processor and processor to controller. Since Schrems II, exporters relying on SCCs must assess the destination's law and practice and add supplementary measures where the clauses alone cannot ensure essentially equivalent protection.; See alsoTransfer impact assessment (TIA)Supplementary measures UK Addendum
Article 49 derogations: Narrow exceptions in GDPR Article 49 that allow a transfer without adequacy or Article 46 safeguards, for example explicit informed consent, necessity for a contract with the data subject, important reasons of public interest, legal claims or vital interests. The EDPB's Guidelines 2/2018 say they must be read restrictively and suit occasional, non-repetitive transfers. They are not a basis for systematic flows such as routine AI inference traffic.; See alsoChapter V (GDPR)Adequacy decision Article 46 standard contractual clauses (SCCs)

B2

Binding corporate rules (BCRs): Group-wide data protection policies approved by a competent supervisory authority under GDPR Article 47, through the EDPB consistency mechanism. Once approved, they let a multinational group transfer personal data between its own entities in third countries. Controller BCRs and processor BCRs exist. Approval takes time and covers only transfers inside the group, so transfers to an outside model provider still need their own tool.; See alsoArticle 46 standard contractual clauses (SCCs)Chapter V (GDPR)
BYOK (bring your own key): A key management model in which the customer generates encryption keys under its own control and imports them into, or links them to, a provider's key management service. The customer can rotate or revoke the key and so cut off the provider's ability to decrypt stored data. It differs from hold-your-own-key or external key management, where the key never leaves a customer HSM and each cryptographic operation calls out to it.; See alsoHardware security module (HSM)CLOUD Act Sovereign cloud

C4

Chapter V (GDPR): Articles 44 to 50 of the GDPR, which govern transfers of personal data to third countries and international organisations. A transfer is lawful only on the basis of an adequacy decision (Article 45), appropriate safeguards such as SCCs or BCRs (Articles 46 and 47) or a narrow derogation (Article 49), and onward transfers must keep the same level of protection. The EDPB's Guidelines 05/2021 set out when an exchange of data counts as a transfer.; See alsoAdequacy decision Article 46 standard contractual clauses (SCCs)Article 49 derogations Schrems II
CLOUD Act: The US Clarifying Lawful Overseas Use of Data Act of 2018, which amended the Stored Communications Act. It requires US providers of electronic communication and remote computing services to disclose data in their possession, custody or control in response to valid US legal process, regardless of where the data is stored, with limited grounds to challenge. It also allows executive agreements with partner countries, such as those with the UK and Australia.; See alsoFISA Section 702 Data sovereignty Zero data retention (ZDR)
Control plane: The management layer of a distributed system. It stores configuration, tenants, policy versions and key metadata, and distributes them to the data planes that handle live traffic, without carrying request payloads itself. Its location still matters for residency because it holds account and configuration data. YTT Secunet's multi-tenant control plane runs in Frankfurt am Main with a Paris standby, on EU-headquartered infrastructure.; See alsoData plane Air-gapped deployment
Controller: Under GDPR Article 4(7), the person or body that determines the purposes and means of processing personal data, alone or jointly with others. The controller carries accountability for compliance, including the lawful basis, transfers and DPIAs. When a company adds an AI feature to its product, it is normally the controller for the prompts its users submit, while the model provider and any gateway in the path act as processors.; See alsoProcessor Article 28 processor terms DPIA (data protection impact assessment)

D7

Data localisation: A legal requirement that certain data be stored or processed inside a particular country or region, sometimes with a ban on copies abroad. Examples include the French HDS certification, which requires certified hosts to keep health data physically inside the EEA, and Saudi rules for government and classified data. Localisation is imposed by law, whereas residency is usually a contractual or architectural choice that an organisation makes for itself.; See alsoData residency Data sovereignty HDS (Hébergeur de Données de Santé)
Data plane: The part of a system that handles live requests. In an AI gateway, the data plane receives the prompt, evaluates policy, masks identifiers, forwards the call to a model endpoint, streams the completion back and signs the receipt. Its physical location determines where prompts are processed in transit, so YTT Secunet runs separate regional data planes for the EU, UK, Switzerland, the GCC, APAC and the US.; See alsoControl plane Egress In-jurisdiction failover
Data Privacy Framework (DPF): The EU-US Data Privacy Framework, recognised by a Commission adequacy decision of 10 July 2023. It covers only US organisations that self-certify with the US Department of Commerce, and rests on safeguards in Executive Order 14086, including the Data Protection Review Court. The EU General Court dismissed an annulment action against it in Latombe v Commission (T-553/23) on 3 September 2025, and an appeal was lodged with the Court of Justice.; See alsoAdequacy decision Schrems II FISA Section 702
Data residency: The physical location where data is stored and processed, usually fixed by contract or configuration. For AI inference, residency means the region where the prompt is processed, not only where logs are stored. Residency does not settle every question on its own: remote access from another country can still be a transfer, and the provider's corporate nationality decides which governments can compel it to hand data over.; See alsoData sovereignty Data localisation Egress
Data sovereignty: The principle that data is subject to the laws and governance of a particular jurisdiction, and the practical goal of keeping it beyond the reach of other jurisdictions' laws. In cloud and AI procurement the question usually becomes who operates the service, who holds the keys and which governments can compel the operator. Where the data sits is only one part of that answer, which is why residency and sovereignty are not interchangeable.; See alsoData residency Sovereign cloud CLOUD Act
DORA (Digital Operational Resilience Act): Regulation (EU) 2022/2554 on digital operational resilience for the financial sector, applicable from 17 January 2025. It sets requirements for ICT risk management, incident reporting, resilience testing and ICT third-party risk, including mandatory contract provisions and a register of information, and creates an EU oversight framework for critical ICT third-party providers. Model providers and AI gateways used by banks and insurers are ICT third-party service providers under DORA.; See alsoRegister of information NIS2 Directive
DPIA (data protection impact assessment): The assessment GDPR Article 35 requires before processing that is likely to result in a high risk to individuals, for example large-scale processing of special category data or systematic monitoring. It describes the processing, tests necessity and proportionality, assesses risks and records the measures that address them. If high residual risk remains, Article 36 requires prior consultation with the supervisory authority. A routing gateway supplies evidence for a DPIA but does not replace one.; See alsoFundamental rights impact assessment (FRIA)Transfer impact assessment (TIA)Controller

E3

Ed25519: A digital signature scheme using EdDSA over the edwards25519 curve with SHA-512, specified in RFC 8032. It has 32-byte public keys and 64-byte signatures, signs deterministically without a per-signature random number, and is fast to verify, which suits signing every API response. RFC 8037 defines its use in JOSE, so an Ed25519 signature can protect a JWS. YTT Secunet signs its residency receipts with Ed25519.; See alsoJSON Web Signature (JWS)Hardware security module (HSM)Proof-of-residency receipt
Egress: Traffic leaving a network, region or jurisdiction. For residency, egress means every path by which a prompt, completion or derivative can leave: the inference call itself, SDK retries that fall back to a global endpoint, telemetry exporters, crash dumps, support tickets and log shipping. Egress controls include allowlisted destinations, private endpoints and firewall rules, and a residency review should list every egress path, not only the main API call.; See alsoData plane Data residency TLS certificate thumbprint
EU Data Boundary: Microsoft's commitment to store and process customer data and pseudonymized personal data for its core enterprise cloud services, including Microsoft 365, Dynamics 365, Power Platform and most Azure services, within the EU and EFTA. It was delivered in phases and completed in February 2025, when professional services data from technical support was added. For Azure, it covers regional services deployed in EU Data Boundary regions. It is a residency commitment and does not change Microsoft's US parentage.; See alsoData residency Sovereign cloud CLOUD Act

F2

FISA Section 702: Section 702 of the US Foreign Intelligence Surveillance Act (50 U.S.C. 1881a), which authorises the targeting of non-US persons reasonably believed to be outside the United States to acquire foreign intelligence information, with compelled assistance from electronic communication service providers. It was central to the Schrems II judgment. Executive Order 14086 later added necessity and proportionality requirements and a redress mechanism that the 2023 adequacy decision relies on.; See alsoCLOUD Act Schrems II Data Privacy Framework (DPF)
Fundamental rights impact assessment (FRIA): The assessment required by Article 27 of the EU AI Act before certain deployers first use a high-risk AI system. It applies to bodies governed by public law, private entities providing public services, and deployers of Annex III systems for creditworthiness assessment and for risk assessment and pricing in life and health insurance. The deployer describes the use, affected groups, risks of harm, human oversight and mitigation, then notifies the market surveillance authority of the results.; See alsoDPIA (data protection impact assessment)High-risk AI system Annex IV technical documentation

G1

General-purpose AI (GPAI) model: Under Article 3(63) of the EU AI Act, an AI model trained on large amounts of data, typically with self-supervision at scale, that displays significant generality and can competently perform a wide range of distinct tasks. Providers of GPAI models have had obligations since 2 August 2025, including technical documentation, information for downstream providers, a copyright policy and a public summary of training content. Models with systemic risk carry further duties under Article 55.; See alsoHigh-risk AI system Annex IV technical documentation

H3

Hardware security module (HSM): A tamper-resistant device that generates, stores and uses cryptographic keys without exposing them to the host system. HSMs are usually validated under FIPS 140-2 or FIPS 140-3, or certified under Common Criteria. On YTT Secunet Sovereign Dedicated, the Ed25519 keys that sign residency receipts can be generated and held in the customer's own HSM, so every signature traces back to a key the customer controls.; See alsoBYOK (bring your own key)Ed25519 Air-gapped deployment
HDS (Hébergeur de Données de Santé): The French certification for hosting personal health data on behalf of others, based on Article L.1111-8 of the Public Health Code. Hospitals, health software vendors and digital health services must use an HDS-certified host for such data. The revised HDS referential published in 2024 requires certified hosts to keep health data physically within the EEA and to be transparent about any risk of access from outside the EU.; See alsoData localisation Special category data
High-risk AI system: An AI system classified as high-risk under Article 6 of the EU AI Act: either a safety component of a product covered by the Union harmonisation legislation in Annex I, or a use case listed in Annex III, such as employment, credit scoring, insurance pricing, education or access to essential services. Providers must meet requirements on risk management, data governance, Annex IV documentation, logging, transparency, human oversight, accuracy and cybersecurity. The 2026 Digital Omnibus on AI pushed back the dates from which these obligations apply.; See alsoAnnex IV technical documentation Fundamental rights impact assessment (FRIA)General-purpose AI (GPAI) model

I3

In-jurisdiction failover: Failover in which every alternative endpoint sits inside the same legal jurisdiction as the primary. If a Frankfurt endpoint fails, traffic moves to Dublin or Amsterdam, never to Virginia, and if no compliant endpoint is healthy the request is refused rather than sent abroad. The point is to stop an outage from turning into an unplanned transfer that would need its own Chapter V basis.; See alsoData plane Policy pack Chapter V (GDPR)
Inclusion proof: The short list of sibling hashes that links one leaf of a Merkle tree to the published root. A verifier hashes the leaf, combines it with each sibling in turn and checks that the result equals the root. The proof grows with the logarithm of the tree size, so about twenty hashes cover a million leaves, and it proves one receipt was included without revealing any other receipt in the tree.; See alsoMerkle tree Proof-of-residency receipt
International Data Transfer Agreement (IDTA): The UK's standalone transfer contract, issued by the Information Commissioner's Office and in force since 21 March 2022 as an appropriate safeguard for restricted transfers under the UK GDPR. It is an alternative to using the EU SCCs with the UK Addendum. Organisations relying on it must also carry out a transfer risk assessment, the UK counterpart of the EU transfer impact assessment.; See alsoUK Addendum Transfer impact assessment (TIA)Article 46 standard contractual clauses (SCCs)

J1

JSON Web Signature (JWS): A standard format, defined in RFC 7515, for content protected by a digital signature or MAC and represented with JSON structures. The compact serialization joins a base64url-encoded header, payload and signature with dots, so it fits in an HTTP header. YTT Secunet returns each residency receipt as a JWS signed with Ed25519 in the X-YTT-Proof-Signature response header.; See alsoEd25519 Proof-of-residency receipt

M1

Merkle tree: A tree of hashes in which each leaf is the hash of a record and each parent is the hash of its children, so the single root hash commits to every record. Changing, removing or reordering any record changes the root. Certificate Transparency (RFC 6962) uses this structure for public logs. YTT Secunet builds an hourly SHA-256 Merkle tree over all residency receipts and publishes each root.; See alsoInclusion proof Proof-of-residency receipt

N2

National Data Management Office (NDMO): The Saudi body, part of the Saudi Data and Artificial Intelligence Authority (SDAIA), responsible for national data governance policy. It issues data management and personal data protection standards and data classification rules that apply to government entities and to companies processing government data on their behalf. Classified government data carries strict localisation expectations, which shapes how AI workloads for Saudi public sector clients must be hosted.; See alsoSaudi PDPL Data localisation
NIS2 Directive: Directive (EU) 2022/2555 on a high common level of cybersecurity across the Union, which member states had to transpose by 17 October 2024. It covers essential and important entities in many sectors, including digital infrastructure such as cloud and data centre services. It requires cybersecurity risk management measures, including supply chain security, staged incident reporting starting with an early warning within 24 hours, and accountability for management bodies.; See alsoDORA (Digital Operational Resilience Act)Sovereign cloud

O1

Open Policy Agent (OPA): An open-source, general-purpose policy engine and a graduated project of the Cloud Native Computing Foundation. It separates policy decisions from enforcement: a service sends structured JSON input, and OPA evaluates policies written in Rego to return a decision. OPA runs as a sidecar, a service or an embedded Go library. YTT Secunet embeds OPA in its data path to decide where each inference request may run.; See alsoRego Policy pack

P5

p99 latency: The 99th percentile of response times: 99 out of every 100 requests finish at or below this value. Averages hide slow outliers, and in interactive AI products the slowest requests are the ones users notice, so gateway budgets are set on tail latency. YTT Secunet's production telemetry shows under 8 ms p99 added latency, covering policy evaluation and receipt minting.; See alsoData plane In-jurisdiction failover
Policy pack: A versioned bundle of Rego policies, reference data and tests that encodes the routing rules for one regulatory regime. YTT Secunet ships packs such as eu-gdpr-strict, uk-gdpr-idta, swiss-fadp-compliant, eu-ai-act-high-risk, saudi-pdpl-sovereign and us-hipaa-only, and customers on Enterprise can add their own rules. The pack id and version are written into every residency receipt, so an auditor can see which rules applied to each request.; See alsoRego Open Policy Agent (OPA)Proof-of-residency receipt
Processor: Under GDPR Article 4(8), a person or body that processes personal data on behalf of a controller. A processor may act only on the controller's documented instructions, including on transfers to third countries, and must be bound by Article 28 terms. Model providers, cloud platforms and AI gateways are usually processors for the prompts their customers send, and a processor's own transfers are subject to Chapter V as well.; See alsoController Subprocessor Article 28 processor terms
Proof-of-residency receipt: YTT Secunet's signed record of where a single inference request was processed. It covers the request hash, policy pack id and version, resolved endpoint, provider region id, facility identifier, upstream TLS certificate SHA-256 thumbprint, model id, zero data retention flag and timestamp, and is returned as an Ed25519-signed JWS in the X-YTT-Proof-Signature header. Each receipt becomes a leaf in an hourly Merkle tree that the open-source ytt-verify tool checks offline.; See alsoJSON Web Signature (JWS)Merkle tree Inclusion proof TLS certificate thumbprint
Pseudonymization: Under GDPR Article 4(5), processing personal data so that it can no longer be attributed to a specific person without additional information that is kept separately and protected. Pseudonymized data remains personal data for whoever can re-identify it. In EDPS v SRB (C-413/23 P, 4 September 2025), the Court of Justice held that it may not be personal data for a recipient who cannot reasonably re-identify the individuals concerned.; See alsoAnonymization Tokenization vault Supplementary measures

R3

Register of information: The register that DORA Article 28(3) requires every financial entity to keep of all contractual arrangements for ICT services provided by third parties, at entity, sub-consolidated and consolidated level. Its templates are set by Commission Implementing Regulation (EU) 2024/2956, and competent authorities collect it periodically. An AI model provider, a gateway and their relevant subcontractors each need to appear, with the functions they support.; See alsoDORA (Digital Operational Resilience Act)Subprocessor
Rego: The declarative policy language of Open Policy Agent, inspired by Datalog. Rules define values and decisions from the input document and reference data, and policies can be unit tested with the opa test command. OPA 1.0 made the Rego v1 syntax the default. In YTT Secunet, Rego rules compute the permitted jurisdiction, the endpoint set and the failover order for each request.; See alsoOpen Policy Agent (OPA)Policy pack
revFADP (Swiss Federal Act on Data Protection): Switzerland's revised Federal Act on Data Protection, also known as the nDSG or nLPD, in force since 1 September 2023 and supervised by the Federal Data Protection and Information Commissioner (FDPIC). Personal data may be disclosed abroad to countries the Federal Council lists as adequate, or under safeguards such as recognised standard contractual clauses. Unlike the GDPR, it provides for criminal fines of up to CHF 250,000 against responsible individuals.; See alsoAdequacy decision Article 46 standard contractual clauses (SCCs)

S6

Saudi PDPL: Saudi Arabia's Personal Data Protection Law, issued by Royal Decree M/19 and later amended, in force since 14 September 2023 with enforcement from 14 September 2024 after a one-year grace period. The Saudi Data and Artificial Intelligence Authority supervises it. Transfers outside the Kingdom are governed by a dedicated transfer regulation that relies on adequacy, appropriate safeguards such as standard contractual clauses, and risk assessments in defined cases.; See alsoNational Data Management Office (NDMO)UAE PDPL Data localisation
Schrems II: The Court of Justice judgment in Case C-311/18, Data Protection Commissioner v Facebook Ireland and Maximillian Schrems, of 16 July 2020. It invalidated the EU-US Privacy Shield because US surveillance law lacked proportionality and effective redress. It upheld standard contractual clauses but required exporters to verify, case by case, whether the destination's law allows the clauses to be honoured, adding supplementary measures where it does not.; See alsoSupplementary measures Transfer impact assessment (TIA)FISA Section 702
Sovereign cloud: A cloud offering designed to keep data, operations and control under one jurisdiction's law: in-region hosting, operations staff based in that region, customer-controlled keys and, in the strictest forms, local ownership. France's SecNumCloud qualification, for example, includes requirements on protection from non-EU laws. The term is used loosely, so buyers should ask who operates the service, who holds the keys and which law governs the operator.; See alsoData sovereignty EU Data Boundary BYOK (bring your own key)
Special category data: The personal data listed in GDPR Article 9(1): racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data used to identify a person, health data, and data on sex life or sexual orientation. Processing is prohibited unless an Article 9(2) condition applies. Free-text prompts in health, HR and insurance use cases often contain it without anyone planning for it.; See alsoDPIA (data protection impact assessment)HDS (Hébergeur de Données de Santé)Pseudonymization
Subprocessor: A processor engaged by another processor to carry out part of the processing for a controller. GDPR Article 28(2) and (4) require the controller's prior specific or general written authorisation, the same data protection obligations flowed down by contract, and notice of changes with a chance to object. The location of every subprocessor matters for Chapter V, because a subprocessor in a third country creates a transfer of its own.; See alsoProcessor Article 28 processor terms Register of information
Supplementary measures: Technical, contractual or organisational measures added to a transfer tool when a transfer impact assessment shows the tool alone cannot ensure essentially equivalent protection. The EDPB's Recommendations 01/2020, adopted in final form on 18 June 2021, treat strong encryption or pseudonymization with keys kept in the EEA as effective. They found no effective measure where the importer needs data in the clear, which is why identifiers are masked before inference.; See alsoSchrems II Transfer impact assessment (TIA)Pseudonymization

T3

TLS certificate thumbprint: A hash, usually SHA-256, of the DER-encoded X.509 certificate a server presents during the TLS handshake. It identifies one exact certificate, which in turn names the endpoint hostname the client connected to. YTT Secunet records the upstream certificate thumbprint in each residency receipt, so an auditor can match a request to the specific provider endpoint and compare it with the inventory in the Sovereign Endpoints registry.; See alsoProof-of-residency receipt Egress
Tokenization vault: A protected store that maps sensitive values, such as names, IBANs or national ID numbers, to surrogate tokens and allows authorised reversal. In YTT Secunet the vault stays in the origin jurisdiction: identifiers in a prompt are replaced with tokens before the request leaves, the model works with the tokens, and the original values are restored in the response before it reaches the user.; See alsoPseudonymization Supplementary measures Anonymization
Transfer impact assessment (TIA): The documented assessment, required since Schrems II for transfers based on Article 46 tools, of whether the law and practice of the destination country could prevent the importer from honouring the safeguards. Following the EDPB's six-step method in Recommendations 01/2020, it maps the transfer, identifies the tool, assesses the destination's law and records any supplementary measures. For AI routing, the TIA should also cover failover paths.; See alsoArticle 46 standard contractual clauses (SCCs)Supplementary measures Schrems II

U2

UAE PDPL: Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, the UAE's federal data protection law, overseen by the UAE Data Office. It does not apply in financial free zones with their own data protection laws, such as the DIFC and ADGM, and some sectors such as health have separate rules. Cross-border transfers are allowed to jurisdictions with adequate protection or under defined alternative conditions.; See alsoSaudi PDPL Data localisation
UK Addendum: The International Data Transfer Addendum to the European Commission's standard contractual clauses, issued by the UK Information Commissioner's Office and in force since 21 March 2022. Attaching it to the EU SCCs makes them valid for restricted transfers under the UK GDPR, so one contract can cover both EU and UK transfers. Like the IDTA, it needs to be backed by a transfer risk assessment.; See alsoInternational Data Transfer Agreement (IDTA)Article 46 standard contractual clauses (SCCs)

Z1

Zero data retention (ZDR): An arrangement in which prompts and completions are processed in memory and not written to disk, not kept after the request completes and not used for training. Model providers offer ZDR on varying terms, sometimes only on approval or for eligible endpoints, and abuse monitoring retention can still apply unless it is waived. YTT Secunet operates with zero data retention and records the upstream ZDR flag in each residency receipt.; See alsoProof-of-residency receipt CLOUD Act

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