The problem this pattern solves
A growing number of jurisdictions explicitly prohibit transferring personal data out of the country — or impose burdensome conditions that make centralising PII in one cloud region commercially impractical. Examples:| Jurisdiction | Law / framework | Localisation stance |
|---|---|---|
| EU / EEA | GDPR (Chapter V transfers) | Cross-border transfers require an Article 45 adequacy decision, Article 46 safeguards, or SCCs. |
| India | DPDPA | Cross-border transfers permitted only to whitelisted countries; sensitive data subject to stricter rules. |
| Russia | Federal Law 152-FZ | Personal data of Russian citizens must be stored and primarily processed inside Russia. |
| Turkey | KVKK | Cross-border transfer requires explicit consent or KVKK Board approval. |
| Saudi Arabia | PDPL | Restrictions on cross-border transfer of personal data of residents. |
| Brazil | LGPD | Cross-border transfer permitted under specific legal bases, with ANPD oversight. |
| China | PIPL | Strict cross-border transfer requirements, including CAC security assessment for large processors. |
The pattern
Deploy a separate Databunker Pro instance in each jurisdiction where you hold PII. Each instance is:- Independent — its own database, its own master key, its own wrapping key, its own audit log.
- In-region — deployed on local cloud infrastructure (AWS Mumbai, Azure Russia, etc.) or local on-prem hardware.
- Operated locally if local law requires (operator citizenship, residency, or licensing constraints).
The next-order problem: operating privacy across N vaults
Once an organisation has five, ten, or fifteen regional Pro deployments, the privacy office faces a new problem:- A data subject in India submits a DSAR through the company’s global website. How does the DPO team find their data without logging into the Indian Pro instance separately?
- A consent withdrawal in Brazil needs to propagate to every system that holds the user’s data — but the regional vaults are intentionally air-gapped at the PII level.
- A compliance report for the EU board needs aggregated metrics (number of records, DSAR counts, consent rates) across every region.
The unifier: Databunker DPO
Databunker DPO is the operational layer designed for exactly this scenario. DPO connects to each regional Pro deployment over an authenticated channel and gives the privacy office a single UI spanning the full estate, with the critical property that:- Minimises the chance of PII leaving its home jurisdiction. By design, only operational signals flow through DPO — DSAR tickets, consent state transitions, audit summaries, processing-activity metadata, aggregated metrics. Raw PII is never required for these operations, so under normal operation it stays inside the regional vault. Customers remain responsible for configuring DPO and any custom workflows to honour their local data-localisation constraints.
- Each regional Pro deployment continues to enforce its own access control, audit, and key custody locally.
DPO deployment options
| Option | When to use |
|---|---|
| SaaS (default) | DPO hosted in the Databunker Portal. The privacy team logs in via the web. Best for most customers. |
| Self-hosted | Enterprise customers who require the operational layer to also run inside their own perimeter (e.g., highly regulated industries, sovereign clouds) can self-host DPO. |
When NOT to use this pattern
This pattern is for organisations operating in multiple jurisdictions with localisation constraints. If you operate in a single jurisdiction, or in multiple jurisdictions without conflicting localisation rules, the right tool is multi-tenancy inside a single Pro instance — it gives cryptographic per-domain isolation without the operational overhead of running N deployments.| Use one Pro + multi-tenancy when | Use multi-jurisdiction Pro deployments when |
|---|---|
| Single jurisdiction. | Multiple jurisdictions with localisation laws. |
| Multiple security domains, one legal home. | Each region’s PII is legally required to stay in-region. |
| One operations team. | Local operations possibly required by law. |
Related
- Multi-tenancy — per-instance tenant isolation (different concern).
- Architecture — core single-instance architecture.
- Security overview — sovereignty and key custody guarantees that make this pattern work.
- Databunker DPO — the operational unifier across regional Pro deployments.