Hybrid cloud and digital sovereignty for EU compliance
- Cedric KTORZA
- 6 days ago
- 7 min read
Hybrid cloud and digital sovereignty are the twin pillars of EU-ready IT. This article explains how to design, operate, and govern a hybrid architecture that meets European requirements while keeping control over data, workloads, and suppliers.
In brief
Build a hybrid model that keeps sensitive data and keys in EU-controlled environments while using public cloud for elastic workloads.
Align with GDPR, NIS2, Schrems II, the EU Data Act, and emerging EU cloud certification to guide technical and contractual choices.
Reduce extraterritorial exposure (e.g., CLOUD Act) via EU data residency, client-held encryption keys, and robust exit strategies.
Prove compliance with evidence: data maps, key management logs, incident runbooks, portability tests, and continuous monitoring.
At Score Group, Noor ITS, Noor Technology, and Noor Energy combine to deliver secure infrastructure, automation, and efficient data center operations.
EU digital sovereignty in practice
The regulatory landscape you must translate into architecture
GDPR remains the baseline for data protection in the EU, setting principles like data minimisation, purpose limitation, and strong access control (2018) Official text.
NIS2 requires enhanced risk management and timely incident reporting for essential and important entities (transposition due by 17 Oct 2024) Directive.
Schrems II (2020) invalidated Privacy Shield; the new EU–US Data Privacy Framework was adopted in 2023, but exporters must still assess transfers and apply safeguards Commission overview.
The EU Data Act entered into force in 2024, with most provisions applying from 2025, including switching and porting obligations to reduce vendor lock-in Data Act policy page and Q&A.
EUCS (EU Cybersecurity Certification Scheme for cloud services) is being prepared by ENISA to harmonize assurance levels and sovereignty controls ENISA cloud certification.
Digital sovereignty is not a single product; it is a continuous capability to decide where data resides, who can access it, and how you can move or exit at any time.
Operational sovereignty: beyond residency
Data control: client-held keys, EU-based HSMs, strict role-based access, and segregation of duties.
Portability and reversibility: tested exit plans, standard formats, and minimal proprietary services.
Transparency: audit-ready logs, supplier attestations, and continuous risk assessment.
Resilience: business continuity planning (BCP), disaster recovery (DR), and supply-chain assurance.
Why hybrid cloud is the pragmatic path
Balance sensitivity, performance, and compliance
Place highly sensitive or regulated data (e.g., personal, health, industrial, or critical infrastructure) in EU-controlled private clouds or trusted sovereign regions.
Leverage public cloud for burst capacity, analytics, and non-sensitive services, while keeping clear data boundaries and lifecycle rules.
Reduce extraterritorial exposure
The US CLOUD Act can compel disclosure from providers subject to US jurisdiction, even for data stored abroad. Limit exposure via EU-hosted workloads, EU legal entities, and client-controlled encryption keys CLOUD Act bill text.
For international transfers, follow EDPB recommendations on supplementary measures (e.g., strong encryption, split processing) EDPB guidance.
Achieve resilience without over-rotation
Hybrid enables local latency, on-premises continuity for critical operations, and cloud elasticity for variable demand—while avoiding single-provider concentration risk.
A reference architecture for EU-aligned hybrid cloud
1) EU-private cloud as the trust anchor
Build or extend an EU-hosted private cloud (VMs/containers) with HSM-backed key management and confidential computing where available.
Enforce strict network segmentation, micro-segmentation, and least privilege.
2) Public cloud with EU data boundaries
Use EU regions and data residency controls; store encryption keys in EU HSMs you control.
Prefer services with clear data-at-rest and data-in-use guarantees; avoid opaque cross-region telemetry for sensitive contexts.
3) Edge for OT/IoT and real-time use cases
Process time-critical data locally; forward only aggregates to the cloud.
Apply hardened gateways, signed firmware, and lifecycle management. See ENISA guidance for critical infrastructure cloud security patterns ENISA publication.
4) Zero Trust identity and access
Centralize identity, enforce MFA, device posture checks, and just-in-time privileged access.
Align to NIST SP 800-207 Zero Trust tenets for policy enforcement and segmentation NIST 800-207.
5) Data management and protection
Classify data; apply tokenization/pseudonymization for analytics; minimize raw PII propagation.
Implement DLP, field-level encryption, and privacy-aware logging. Use transfer impact assessments and SCCs when needed.
6) Connectivity and observability
Use encrypted SD-WAN and private links; apply CASB/SASE for cloud access.
Centralize logs and metrics; standardize evidence collection for audits (access logs, key usage, change records).
“Design for exit on day one.” Prefer cloud-agnostic tooling (Kubernetes, Terraform, open standards) and periodically test portability.
Governance and compliance-by-design
Data mapping and risk-driven placement
Maintain a living data map with owners, categories, processing purposes, storage locations, and transfer pathways.
Tie workloads to allowed landing zones (private, EU public region, global) based on risk and legal basis.
Supplier due diligence and reversibility
Assess providers for EU legal entity control, support for EU data residency, key management options, and portability SLAs.
Plan migrations with reversible patterns (images, containers, Infrastructure as Code) and negotiate exit support.
Incident response and continuity (NIS2-aware)
Define detection thresholds, early warning and notification playbooks, and cross-entity escalation paths.
Test DR scenarios (RTO/RPO), including loss of a cloud region or identity provider, and maintain immutable backups.
How Score Group helps deliver sovereignty with performance
At Score Group, we integrate energy, digital, and new tech so your architecture is secure, efficient, and future-proof. Our Noor ITS division designs and operates the digital backbone: secure networks, data centers, cloud and hosting (private, public, hybrid), cybersecurity, and business continuity (PRA/PCA). Noor Technology brings automation and intelligence with AI, RPA, IoT and smart connectivity to enhance observability and policy enforcement across environments. Noor Energy strengthens the foundation with efficient, sustainable infrastructure—optimizing data center energy use, supporting renewable integration, and enabling smart building systems that reduce your IT carbon footprint.
EU private cloud builds with client-held keys, hardened management planes, and Zero Trust identity.
Hybrid connectivity with encrypted SD-WAN, private cloud–to–public cloud links, and policy-based routing.
Security operations: SIEM/SOAR integration, incident readiness aligned to NIS2, and continuous compliance evidence.
Energy-aware data center optimization to balance performance and sustainability goals.
Explore our mission and approach on the Score Group website: Score Group – Where efficiency meets innovation.
Mapping EU requirements to hybrid cloud controls
FAQ
Do I need a hybrid cloud to achieve digital sovereignty in the EU?
Not always, but hybrid is often the most pragmatic route. It lets you keep sensitive data and keys in EU-controlled environments while using public cloud for elasticity, analytics, or innovation. This split reduces exposure to extraterritorial access and supports data residency, portability, and resilience. If your workloads are low-risk and a provider offers robust EU controls, a single-cloud model may suffice. However, hybrid makes it easier to implement client-held encryption, reversible architectures, and continuity outside any single vendor.
How can I keep data in the EU when using hyperscalers?
Select EU regions and enable data residency controls. Store and manage encryption keys in EU-based HSMs that you control, and restrict support access via just-in-time workflows. Avoid services that replicate metadata outside the EU by default; check logs, telemetry, and backup locations. For cross-border transfers, perform a transfer impact assessment and apply supplementary measures, including encryption and minimisation, per EDPB guidance. Finally, document everything—data flows, configurations, and evidence for audits and DPIAs.
What is the impact of the US CLOUD Act on my cloud choices?
The CLOUD Act can require providers under US jurisdiction to disclose data, even when hosted abroad. To reduce risk, keep sensitive data in EU-hosted environments under EU legal control, adopt client-held or split-key encryption, and prefer services with clear data boundary guarantees. Where transfers are unavoidable, use standard contractual clauses and apply technical safeguards. Evaluate each provider’s legal posture and transparency reports, and include exit strategies in your contracts to preserve optionality.
How do I prove compliance during an audit or regulatory review?
Auditors look for evidence, not intentions. Maintain an up-to-date data inventory and classification, access control matrices, key management logs, and change records. Keep incident response runbooks and test reports (e.g., DR, portability drills). Archive vendor attestations, region residency settings, and encryption configurations. For cross-border data flows, provide transfer impact assessments and agreements. Most importantly, ensure evidence is continuous and automated—collected from source systems and preserved immutably for the required retention period.
What’s the difference between data residency and digital sovereignty?
Data residency is about where data is stored—typically within a geographic boundary such as the EU. Digital sovereignty goes further: it adds who controls access (including encryption keys), how data is processed and moved, and your ability to exit or switch providers without undue friction. Sovereignty includes legal, technical, and operational control. In practice, you need both: residency to respect local laws and sovereignty to ensure autonomy, continuity, and trustworthy operations over time.
Key takeaways
Hybrid cloud enables EU-aligned control: keep sensitive data and keys in EU, use public cloud for scale.
Translate laws into controls: GDPR privacy by design, NIS2 incident readiness, Schrems II safeguards, Data Act portability.
Reduce extraterritorial risk with client-held encryption, EU data boundaries, and reversible architectures.
Prove compliance continuously with automated evidence: logs, maps, runbooks, and test results.
Score Group unifies digital, energy, and new tech to deliver compliant, efficient hybrid platforms.
Ready to move from intent to implementation? Talk to us at Score Group to architect and operate a hybrid cloud that respects EU sovereignty and accelerates your innovation.
