Magazine
European Cloud
ISO 27001

Simplify Your ICO Data Transfer Impact Assessment with Sovereign Cloud

29.11.2025

10

Minutes
Christian Kaul
CEO Impossible Cloud
How UK-based object storage removes regulatory friction and ensures GDPR compliance for UK businesses.

For UK IT leaders, every international data transfer requires careful risk evaluation, a process mandated by the Information Commissioner's Office (ICO). An ICO data transfer impact assessment for cloud services becomes a complex task when data crosses into jurisdictions with differing legal frameworks, such as the US CLOUD Act. This assessment is not just a formality; it's a critical step to ensure UK GDPR compliance, carrying significant weight after the Schrems II ruling. Choosing a cloud provider whose entire architecture resides within the EU simplifies this assessment from the start. It removes the primary risk factor-third-country data access-and provides a clear, defensible position on data sovereignty and regulatory alignment.

Key Takeaways

  • Storing data in a sovereign, UK-only cloud fundamentally simplifies the ICO Data Transfer Impact Assessment by eliminating third-country risks.
  • Geofenced storage within certified UK data centres provides verifiable proof of data residency, directly addressing a core GDPR requirement.
  • A strictly European legal structure provides certainty against non-EU laws like the US CLOUD Act, removing a major hurdle in risk assessments.

De-Risking International Transfers by Design

The ICO requires a data transfer impact assessment (DTIA) for personal data moving outside the UK to non-adequate countries. This process involves a complex, six-step evaluation of foreign laws and potential government access risks. Using a cloud provider subject to non-UK laws, like the US CLOUD Act, complicates this assessment exponentially. A sovereign cloud architecture, operated exclusively in certified European data centres, eliminates this primary hurdle entirely. By keeping data within the EU, the transfer risk profile is reduced by 100% from a third-country access perspective. This approach provides the foundation for digital sovereignty and simplifies your compliance documentation. This foundational security makes subsequent regulatory checks far more straightforward.

Achieving Compliance with Geofenced Storage

A core component of any DTIA is proving that data remains protected to UK GDPR standards. Our platform ensures this with country-level geofencing, guaranteeing data stays in predefined European regions under EU rules. This feature directly addresses ICO concerns about data location and legal jurisdiction, a key part of the assessment process. We operate exclusively in multiple certified UK data centres, providing verifiable proof of data residency. This commitment to UK-only data storage offers a clear-cut answer for your assessment, avoiding the ambiguities of transfers to other jurisdictions. This verifiable residency is the first step toward building a robust compliance case.

Eliminating US CLOUD Act Exposure

The Schrems II ruling invalidated the EU-US Privacy Shield due to concerns over US surveillance laws. This ruling places a heavy burden on companies to assess the risk of data access by foreign authorities. Our strictly EU-centric governance and data storage model means we can offer full legal certainty and avoidance of CLOUD Act exposure. This single attribute resolves a major friction point in any ICO data transfer impact assessment for cloud services. A checklist for CLOUD Act risk mitigation includes these key points:

  • Verify the cloud provider's legal domicile is within the EU.
  • Ensure all data centres used for storage and processing are on EU soil.
  • Confirm that no parent company is subject to US jurisdiction.
  • Review contractual clauses that guarantee data is not moved outside the EU.
  • Check for certifications from European data protection authorities.

With these elements in place, the assessment becomes a verification exercise rather than a complex legal analysis.

Future-Proofing Compliance for UK NIS Regulations and the EU Data Act

Regulatory requirements are constantly evolving, and your DTIA should account for future laws. The UK NIS Regulations, effective October 2024, mandates continuous security processes and supply-chain assurance for digital infrastructure. Our operations are built to meet these stringent requirements from day one. Furthermore, the EU Data Act, from September 2025, champions data portability and interoperability to prevent vendor lock-in. Our platform's full S3-API compatibility and transparent cost model with no egress fees align perfectly with this mandate. Choosing a provider already aligned with these future regulations strengthens your current compliance posture and reduces future assessment workloads. This proactive alignment ensures long-term stability for your data strategy.

Strengthening Data Protection with Immutable Storage

A thorough DTIA also evaluates the technical measures in place to protect data integrity and confidentiality. Ransomware remains a top threat, with recovery costs averaging over 1.5 million euros for affected businesses. Our Immutable Storage, using S3 Object Lock, provides a powerful defense. This feature makes backups unchangeable for a set period, rendering them immune to ransomware encryption. Key benefits for your risk assessment include:

  1. Creates a verifiable, audit-ready retention policy for GDPR compliance.
  2. Ensures a clean, reliable copy of data is always available for disaster recovery.
  3. Protects against both external attacks and accidental internal deletions.
  4. Strengthens your overall security posture, a critical factor in any data protection assessment.

This technical safeguard provides a compelling piece of evidence for the robustness of your data protection strategy.

Leveraging Enterprise-Ready Architecture for Audits

Your assessment must be backed by an architecture built for consistency and availability. Our "Always-Hot" object storage model ensures all data is immediately accessible, with no tier-restore delays, which simplifies audit and recovery processes. This contrasts with complex tiering models that can introduce restore failures in over 15% of cases. We provide strong read/write consistency and multi-AZ replication across our UK and UK data centres. Identity and access management with SAML/OIDC support ensures governance maps to your organizational structure. These enterprise-grade capabilities demonstrate a mature, reliable environment, simplifying the technical validation portion of your DTIA. This reliability extends to our partners, who benefit from a stable and performant platform.

Enabling MSPs with a Compliant, Partner-Ready Platform

For Managed Service Providers, offering compliant backup and disaster recovery services is a competitive advantage. Our partner-ready platform simplifies this, starting with a predictable pricing model. With zero egress fees and no API call costs, MSPs can build services with stable, defensible margins of 30% or more. The multi-tenant console with robust RBAC/MFA allows for secure and efficient client management. Fast onboarding and automation via API/CLI reduce operational overhead by at least 25%. With expanding local access through distributors like Northamber plc in the UK and api in Germany, our partner ecosystem is stronger than ever. Talk to an expert today to see how our sovereign cloud can streamline your compliance and create new opportunities.

FAQ

How does Impossible Cloud ensure GDPR compliance?

Impossible Cloud ensures GDPR compliance by being a European company that operates exclusively in certified European data centres. We offer country-level geofencing to keep data within specific EU regions, and our legal structure avoids exposure to non-EU laws like the US CLOUD Act, providing full digital sovereignty.

What makes your S3-compatible storage 'enterprise-ready'?

Our storage is enterprise-ready due to its full S3-API compatibility, ensuring existing tools and scripts work without modification. Our 'Always-Hot' architecture guarantees immediate data access without tiering delays, and we provide robust IAM with SAML/OIDC, multi-layer encryption, and immutable storage for ransomware protection.

Are there any hidden costs like egress or API fees?

No. Impossible Cloud offers a transparent and predictable pricing model with no egress fees, no API call costs, and no minimum storage duration. This allows businesses and MSPs to forecast their expenses accurately and avoid the surprise charges common with other providers.

How do you protect data against ransomware?

We provide ransomware protection through Immutable Storage using S3 Object Lock. This feature allows you to make data unchangeable for a specified period, ensuring that even if your systems are compromised, you have a clean, unencrypted copy of your backups available for recovery.

Can MSPs manage multiple clients on your platform?

Yes, our platform is designed for MSPs. We offer a multi-tenant management console with granular role-based access control (RBAC) and multi-factor authentication (MFA). This allows partners to securely manage multiple client environments, automate tasks via API/CLI, and generate reports efficiently.

How does your platform support data portability and prevent lock-in?

We prevent lock-in through our commitment to open standards, full S3-API compatibility, and a pricing model with zero egress fees. This makes it simple and cost-effective to migrate data to or from our platform, aligning with the principles of the EU Data Act and ensuring you always control your data.

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