Data residency & management

Find your data, bring it home, and govern it properly

Almost every organisation we assess believes its customer data is in the UAE. Almost every assessment finds some of it is not. We map the real picture, migrate what sits offshore, and leave behind a governed system with evidence attached.

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Where residency usually breaks

The database is rarely the problem

The CBUAE Consumer Protection Standards require consumer and transaction data to be held and stored inside the UAE. That covers the copies, not just the original.

Backups and disaster recovery

Replication to a cheaper offshore region is the single most common finding. The production database is compliant; the nightly snapshot crossing a border is not.

Logs and observability

Error tracking, log aggregation and performance monitoring tools routinely capture personal data in payloads and ship it to overseas processing regions by default.

Third-party SaaS

CRM, helpdesk, e-signature, marketing automation and survey tools. Each one is an outsourcing relationship the Standards expect you to have assessed and contracted for.

Key management

Data encrypted at rest in the UAE with keys held in an offshore key management service leaves the residency argument resting on the wrong jurisdiction.

CDN and edge caching

Edge nodes caching authenticated responses can hold personal data in dozens of countries without anything appearing in an architecture diagram.

Analytics and session replay

Client-side scripts that capture form fields, identifiers or full session recordings and transmit them to processors outside the UAE.

What we deliver

Discovery, migration, governance, evidence

We map where your customer data actually lives, migrate what sits offshore into UAE data centres, and leave behind a governed system with classification, retention, access control and evidence you can hand a supervisor.

Start with an assessment

Included in every engagement

  • Data discovery and mapping across every system and SaaS vendor
  • Migration of records and backups into UAE-resident infrastructure
  • Data classification, retention schedules and deletion workflows
  • Access governance, logging and least-privilege enforcement
  • Vendor and outsourcing review against CBUAE expectations
  • Evidence pack: architecture, data-flow diagrams, control register

How it runs

Four phases, each with a deliverable you keep

  1. Discover

    We interview system owners, review architecture, inspect vendor contracts and inspect the running estate. Deliverable: a data map showing every location where consumer and transaction data is stored, processed, cached, logged or backed up — with a gap register ranked by exposure.

  2. Design

    Target-state architecture for UAE residency: hosting, key management, replication topology, retention, access model and vendor replacements where a provider cannot offer in-country processing. Deliverable: architecture and data-flow documentation your risk function signs off before migration begins.

  3. Migrate

    Data moved into UAE-resident infrastructure with reconciliation at each step, offshore copies verifiably destroyed, and integrations repointed. Deliverable: a migration record showing what moved, when, and confirmation that the source copies are gone.

  4. Govern

    Classification scheme, retention and deletion schedules that actually execute, access governance with periodic review, and monitoring that flags data leaving the country. Deliverable: a control register with named owners and a re-test cadence.

Evidence pack

What you hand a supervisor

Compliance is a documentation problem as much as an engineering one. Every engagement ends with artefacts, not assurances.

Data map

Every system, every data category, every storage and processing location, with the legal basis noted.

Data-flow diagrams

How records move between systems and vendors, showing where a border is crossed and where it is not.

Control register

Each control, its owner, how it is evidenced, when it was last tested and when it is next due.

Vendor assessments

Where each third party stores and processes data, and how the contract handles exit and onward sharing.

Find out where your data actually is

A structured assessment across your estate, delivered as a data map and a ranked gap register. You keep the findings regardless of what happens next.

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