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T04 Data Residency and Sovereignty Attestation

Verification required. This is a working template, not a regulator-approved form. Where it names a regional instrument, the claim comes from secondary sources and is a pointer to check, not a confirmed legal requirement. This is not legal advice.

How to use: This is a blank form. Copy it and fill in the empty cells and blanks for your system. To copy it, follow the "Suggest an edit to this page" link in the footer to reach its Markdown source.

Wiki control: AI-CTRL-007. The signer attests to facts of configuration, not to legal compliance. Legal review of transfers is separate.

Field Entry
System / use-case ID
Attestation date
Valid until (re-attest on change or at 12 months)
Signer (name, role)

1. Data inventory by location

Data component Description Country Provider and region Legal entity Encrypted (Y/N) Key holder
Training data
Fine-tuning data
Prompts and inputs
Model inference compute
Outputs
Embeddings / vector store
Application logs
Telemetry / monitoring
Backups and snapshots
Support and admin access (location of staff)
Sub-processors

2. Transfers

Flow From To Personal data? Mechanism / basis (per legal advice) Approved by

3. Attestations (tick if true; explain exceptions)

  • [ ] All components above are at the stated locations
  • [ ] No component is replicated outside the stated locations
  • [ ] Vendor staff outside the approved countries cannot access data, or access is logged and approved
  • [ ] Customer data is not used for vendor model training
  • [ ] Deletion removes data from backups within ______ days
  • [ ] Configuration evidence attached (exports, screenshots, region settings)

Exceptions and compensating controls:

4. Regional checks (confirm from primary text; do not rely on this list)

Jurisdiction Question for counsel
UAE mainland Transfer conditions under PDPL; sector localisation rules
DIFC / ADGM Transfer rules under free-zone regulations
Saudi Arabia PDPL transfer conditions; NCA, NDMO, SAMA localisation overlays [Reported, verify]
Qatar PDPPL transfer rules; QCB expectations
Bahrain, Oman PDPL transfer provisions; Oman amendments pending [Reported]

5. Sign-off

Signer: __ Date: _ Reviewed by (privacy/security): Date: ___