GDPR & UK GDPR Compliance

Sovereign communications built for the world's *most powerful data protection regime.*

The General Data Protection Regulation sets the global benchmark for privacy law. SCOVR satisfies every obligation that touches communications infrastructure — structurally, not through policy alone. The same architecture covers both the EU GDPR and the UK GDPR simultaneously.

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EU & UK data residency Art. 28 processor contract included Art. 25 privacy by design — default on
€20M / 4%
EU GDPR maximum fine for serious violations — whichever of €20 million or 4% of global annual turnover is higher
£17.5M / 4%
UK GDPR maximum fine imposed by the ICO — the equivalent tier applies identically to UK-established organisations
72h
Maximum time to notify the supervisory authority following discovery of a qualifying personal data breach — Art. 33
8+
Data subject rights under both regimes — access, rectification, erasure, restriction, portability, objection, and more
Two regimes, one platform

The EU GDPR and UK GDPR share the same architecture — and so does the solution.

Following the departure of the United Kingdom from the European Union, the GDPR was retained as a separate instrument of UK domestic law, supplemented by the Data Protection Act 2018. The two frameworks are substantially identical — meaning a platform that satisfies one satisfies both.

EU GDPR

Regulation (EU) 2016/679

The General Data Protection Regulation applies to any organisation — anywhere in the world — that processes the personal data of individuals located in the EU. It applies from 25 May 2018 and is directly applicable in all EU member states without national implementing legislation.

Supervisory authority: Each member state has its own national data protection authority. The lead authority is determined by the organisation's main EU establishment.

Transfers: Transfers outside the EU require an adequacy decision, standard contractual clauses, binding corporate rules, or another approved mechanism under Chapter 5.

Fines: Up to €10M / 2% (lower tier) or €20M / 4% (upper tier) of total worldwide annual turnover — whichever is higher.

EU Data Act: From 12 September 2025, Regulation (EU) 2023/2854 adds cloud-switching rights and prohibits vendor lock-in in data processing contracts.

UK GDPR

UK GDPR & Data Protection Act 2018

After Brexit, the EU GDPR was retained in UK law and amended to refer to UK institutions. The Data Protection Act 2018 supplements it with UK-specific provisions. The result is a framework that mirrors the EU GDPR in substance while replacing all references to EU bodies with UK equivalents.

Supervisory authority: The Information Commissioner's Office (ICO) is the sole supervisory authority for the UK. The EDPB consistency mechanism does not apply.

Transfers: Transfers from the UK require adequacy regulations, an International Data Transfer Agreement (IDTA), or an Addendum to EU Standard Contractual Clauses.

Fines: Up to £8.7M / 2% (lower tier) or £17.5M / 4% (upper tier) of total worldwide annual turnover — applied by the ICO under the Data Protection Act 2018.

Children's data: The age of digital consent in the UK is 13 (vs. 16 in the EU by default). Organisations processing children's data must satisfy the stricter UK children's code.

Key obligations

Six articles that directly govern how you communicate.

Communications infrastructure — messaging, video, file sharing, and data hosting — touches more GDPR obligations than almost any other category of enterprise software. Each must be satisfied by the platform, not just the policy around it.

Art. 5(1)(f)

Integrity & confidentiality

Personal data must be processed with "appropriate security…including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage." Encryption is the primary technical measure that satisfies this requirement — and it must be applied to every channel carrying personal data: messages, calls, and files.

Art. 25

Privacy by design & default

Appropriate technical measures must be implemented both at the time of system design and at the time of processing. The default settings must ensure that only personal data necessary for each purpose is processed. A platform where encryption must be switched on is not compliant by default — privacy must be the factory setting.

Art. 28

Processor contracts

Every cloud provider, SaaS platform, or infrastructure provider that processes personal data on your behalf must be bound by a written contract covering: scope and purpose of processing, security requirements, sub-processor authorisation, data subject rights support, audit rights, and post-contract data handling. Verbal or implied arrangements are insufficient.

Art. 32

Security of processing

Controllers and processors must implement measures "appropriate to the risk," which the Regulation explicitly identifies as including "the encryption…of personal data" and the ability to ensure "ongoing confidentiality, integrity, availability and resilience" of systems. Certification under Article 42 may be used as evidence of compliance.

Art. 33–34

Breach notification

Qualifying breaches must be notified to the supervisory authority within 72 hours of discovery. High-risk breaches must also be communicated to affected individuals "without undue delay." The architecture of the platform determines whether a breach can occur at scale — and how quickly it can be detected and contained.

Art. 44–49

International transfers

Personal data may only be transferred to a third country if that country provides an adequate level of protection, or if appropriate safeguards are in place (SCCs, BCRs, IDTAs in the UK context). Any cloud service routed through non-adequate jurisdictions — including those subject to foreign surveillance legislation — requires specific legal analysis and safeguards.

Article-by-article mapping

How SCOVR satisfies GDPR obligations structurally.

Every key obligation relating to communications infrastructure is addressed at the platform level — before any policy document is drafted.

Article
GDPR requirement
SCOVR architectural response
Status
Art. 5(1)(c)
Data minimisation
No metadata analytics, behavioural profiling, or content scanning. Processing is limited to what is technically necessary to deliver message routing. No data collected for product improvement on your deployment.
✓ Met
Art. 5(1)(f)
Integrity & confidentiality
End-to-end encryption is the default state on every channel — messages, files, voice, and video. No server operator can access plaintext content. The Rust-based cryptographic implementation is independently auditable.
✓ Met
Art. 25
Privacy by design & default
Encryption and minimum data collection are enabled automatically. No configuration is required to reach the highest privacy level. Privacy is the architecture, not a setting.
✓ Met
Art. 28
Processor contract
A full Data Processing Agreement satisfying all Art. 28(3) requirements is included with every deployment: scope, security measures, sub-processor list, audit rights, and post-contract data handling obligations.
✓ Met
Art. 30
Records of processing activities
The platform generates a full, immutable, exportable audit log of all access events, message delivery records, and administrative actions. This log constitutes the processing register required under Art. 30.
✓ Met
Art. 32
Security of processing
E2EE (pseudonymisation + encryption), self-hosted resilience, role-based access control, and ISO 27001 certification. The open standard codebase enables independent security assessment under Art. 32(3).
✓ Met
Art. 33–34
Breach notification
The isolated, self-hosted architecture eliminates multi-tenant breach risk. Built-in monitoring and alerting support rapid detection. Pre-formatted 72-hour notification documentation is provided for supervisory authority reporting.
✓ Met
Art. 35
Data Protection Impact Assessment
A pre-built DPIA documentation package covering all data flows, encryption mechanisms, access controls, and residual risks is included with deployment. The open codebase allows independent third-party DPIAs without vendor involvement.
Supported
Art. 44–46
International transfer controls
All data is stored on servers within your designated jurisdiction. No traffic is routed through non-adequate third countries. The federated architecture allows cross-organisation communication without creating international transfers.
✓ Met
Art. 15–22
Data subject rights
All data resides within your controlled infrastructure. Access, rectification, erasure, portability, and restriction can all be executed operationally — without submitting requests to a third-party vendor or waiting for their response.
✓ Met
UK GDPR — specific requirements

Post-Brexit obligations for UK-established organisations.

The UK GDPR applies to any organisation established in the UK, or any organisation outside the UK that processes personal data of individuals in the UK in connection with offering goods or services to them or monitoring their behaviour. The framework is enforced exclusively by the ICO.

The most significant practical difference from the EU GDPR concerns international data transfers. Organisations transferring personal data out of the UK may no longer rely on EU Standard Contractual Clauses alone — they must use the International Data Transfer Agreement (IDTA) or an Addendum to the EU SCCs, both published by the ICO.

The Data Protection Act 2018 supplements the UK GDPR in several important areas: it expands lawful bases for processing for public interest and democratic purposes, sets the age of digital consent at 13, and provides specific conditions for processing special categories of data — including through the schedules that replace the more general approach in Article 9 of the EU GDPR.

ICO enforcement is active and substantial. The ICO has the power to issue fines of up to £17.5 million or 4% of global annual turnover, conduct compulsory audits, issue enforcement notices, and pursue criminal prosecution under the Computer Misuse Act 1990 and the Privacy and Electronic Communications Regulations. Regulatory action is increasingly focussed on technical security failures — including inadequate encryption and unauthorised access — rather than purely procedural violations.
UK GDPR — SCOVR compliance features

UK data residency

All data can be hosted within the United Kingdom on SCOVR's sovereign infrastructure. No personal data of UK individuals is transferred to non-adequate third countries — satisfying the IDTA and adequacy requirements for outbound transfers.

IDTA-compatible Data Processing Agreement

The processor contract provided with every UK deployment is aligned with the International Data Transfer Agreement requirements — covering the same obligations as an EU SCCs Addendum for UK-to-third-country transfer scenarios.

ICO-format breach notification support

Pre-formatted breach notification documentation is aligned with the ICO's published reporting template and the 72-hour notification window. Incident response playbooks are included with every deployment.

Children's data safeguards

For organisations operating in education, consumer, or youth-facing sectors, additional controls at the access and room level enforce the data minimisation and processing restrictions required under the UK children's code and DPA 2018 Section 9.

Cyber Essentials Plus accreditation

The platform holds Cyber Essentials Plus accreditation — the UK government's certification scheme for technical security controls — in addition to ISO 27001 certification, providing dual assurance recognised by the ICO and public sector procurement.

Sovereign communications

Every communications channel — satisfying GDPR by design.

Messaging, video conferencing, file sharing, and data hosting each carry distinct GDPR obligations. The architecture addresses all four simultaneously.

Secure messaging

Every message is encrypted end-to-end before leaving the sender's device. No server — including SCOVR's own infrastructure — can read the content. Delivery receipts, read receipts, and thread metadata are minimised. Art. 5(1)(f) and Art. 32 are satisfied by the protocol, not by configuration.

Applies: Art. 5, 25, 28, 32

Video conferencing

Voice and video calls are encrypted with the same E2EE architecture as text messages. No call content is recorded or retained on third-party servers without explicit administrative configuration. No recording is shared with external parties or used for AI model training. Screen sharing operates within the same encrypted session.

Applies: Art. 5, 25, 32, 33

File sharing

Files shared within SCOVR are encrypted in transit and at rest. Files are stored only on your own sovereign infrastructure — not on shared cloud storage services subject to foreign surveillance legislation. Access controls at the room level ensure only authorised recipients can retrieve files. The open standard means file formats are never proprietary.

Applies: Art. 5, 28, 32, 44

Data hosting

All data — messages, files, user profiles, call records, and audit logs — is hosted on servers physically located in the jurisdiction you designate. No data passes through multi-tenant infrastructure shared with other organisations. No third-country transfer occurs unless explicitly and specifically configured with appropriate safeguards.

Applies: Art. 28, 30, 44–46

Why the open standard backbone

The protocol architecture is the compliance argument.

Most enterprise communications platforms are built on proprietary protocols — closed, opaque, and controlled entirely by a single vendor. From a GDPR perspective, this creates structural problems that no Data Processing Agreement can fully resolve: you cannot independently verify what data is being processed, you cannot audit the security implementation, and you cannot guarantee that a future product decision by the vendor will not create a compliance breach.

The open standard protocol on which SCOVR is built was designed by a non-profit foundation specifically to solve this problem. The protocol specification is published, the cryptographic implementation is open source, and any technically competent authority — including a supervisory authority — can audit every processing activity without vendor cooperation.

Decentralised federation means organisations can communicate with external parties — including cross-border partners — without creating an international data transfer in the legal sense. Messages between two federated servers in the same jurisdiction never leave that jurisdiction. This is architecturally different from routing messages through a US-headquartered cloud service, where even intra-EU traffic may be subject to foreign surveillance law.

EU Data Act (Regulation 2023/2854) — applicable from 12 September 2025

The EU Data Act prohibits contractual clauses that restrict cloud switching and requires providers to make data portable in structured, machine-readable formats. Because SCOVR is built on an open standard, migration is a native capability: organisations can switch providers, self-host, or federate with another deployment at any time — without permission, without penalty, and without data loss. No switching charges apply. The open format requirement of Art. 24 is satisfied by the protocol itself.

Open standard architecture — GDPR advantages

Independently auditable — Art. 32

The entire cryptographic stack — including the Rust-based E2EE implementation — is open source and independently auditable. Supervisory authorities, DPOs, and third-party security assessors can verify every claim without vendor cooperation. No black-box components that resist audit.

Federation eliminates transfer risk — Art. 44

Two organisations in the same jurisdiction can communicate via federated servers that never transfer data internationally. A law firm in London communicating with a client using a separate sovereign deployment creates no international transfer. The interoperability is structural, not contractual.

No vendor lock-in — EU Data Act / Art. 28(3)(g)

Data can be exported in open formats at any time. The organisation retains full ownership of its data — the processor contract obligation to return or delete data on termination is a technical capability of the platform, not just a contractual obligation.

No profiling or behavioural analysis — Art. 5(1)(c)

The platform performs no automated profiling of users, no sentiment analysis on messages, and no engagement scoring. Data collection is limited to what is technically necessary for routing and delivery. There is no incentive to collect more — the business model does not depend on data monetisation.

ISO 27001 certification — Art. 42

Certification to ISO/IEC 27001:2022 serves as evidence of compliance with the security requirements of Art. 32 under the certification mechanism of Art. 42. Cyber Essentials Plus (UK) provides additional assurance recognised by the ICO and public sector procurement bodies.

Up to 20,000× faster than legacy platforms

The current generation of the platform, built on Sliding Sync technology, is engineered for speed without compromising security. Performance at scale means encryption does not come at the cost of usability — a critical factor in ensuring that privacy by design does not reduce adoption.

Full compliance coverage

Every GDPR obligation addressed before deployment begins.

Documentation, contracts, and architectural features are bundled with every deployment — no additional procurement, no external consultants needed for the standard compliance requirements.

EU GDPR — Art. 25

Privacy by design, out of the box

End-to-end encryption is enabled on every channel by default — messages, voice, video, and files. No administrator action is required to reach the highest protection level. The Art. 25(2) data minimisation default is satisfied by the protocol: only data necessary for routing and delivery is collected.

EU & UK — Art. 28

Data Processing Agreement included

A written Data Processing Agreement satisfying all requirements of Art. 28(3) is provided with every deployment — covering processing scope, security obligations, the full sub-processor list, audit rights, data subject rights assistance, and post-contract data deletion or return.

EU & UK — Art. 32

ISO 27001 + Cyber Essentials Plus

Platform security is certified to ISO/IEC 27001:2022 (EU and UK recognition) and Cyber Essentials Plus (UK government scheme). These certifications serve as evidence of Art. 32 compliance under the Art. 42 certification mechanism — reducing the burden of due diligence for your legal and procurement teams.

EU & UK — Art. 33–34

Breach notification infrastructure

Pre-built incident response documentation, breach notification templates aligned with both supervisory authority reporting formats (EDPB / ICO), and built-in anomaly monitoring. The isolated architecture significantly reduces the probability of a large-scale breach, and the self-hosted deployment gives you direct control over the investigation.

EU Data Act — Art. 23–29

No vendor lock-in — cloud switching

Migration is a native capability of the open standard architecture. Data exports in structured, machine-readable formats are available at any time. No switching charges apply. Organisations can move to a different provider, self-host, or federate — without permission, penalty, or data loss — satisfying the EU Data Act cloud-switching obligations from day one.

Open standard

Independently auditable protocol

The protocol specification is published and maintained by an independent non-profit foundation. The cryptographic implementation is open source. Any technically competent authority — including national data protection authorities — can audit all processing activities without vendor cooperation. There are no proprietary black-box components.

Questions

Frequently asked.

Specific answers to the GDPR and UK GDPR questions DPOs, legal teams, and IT security leads ask most often.

Does SCOVR qualify as a GDPR-compliant data processor?+
Yes. A written Data Processing Agreement satisfying all requirements of Article 28(3) is included with every deployment. The agreement covers: the subject matter, duration, nature and purpose of processing; the type of personal data and categories of data subjects; and all obligations and rights of the controller. A full sub-processor list, audit rights provision, and data deletion clause are included as standard — not available on request.
How does SCOVR satisfy the security requirements of Article 32?+
Article 32 explicitly identifies encryption and pseudonymisation as appropriate technical measures. SCOVR implements end-to-end encryption by default on every channel — messages, calls, and file transfers — using a Rust-based cryptographic implementation that is open source and independently auditable. The self-hosted architecture ensures ongoing confidentiality, integrity, availability, and resilience of processing systems. ISO/IEC 27001:2022 certification provides evidence of compliance with Art. 32 under the certification mechanism of Art. 42. Cyber Essentials Plus certification provides additional UK assurance.
How does the platform handle international data transfers under Art. 44–46?+
All data is stored on servers physically located in the jurisdiction you designate — by default, the EU or UK as applicable to your deployment. No traffic is routed through third-country infrastructure. The federated architecture allows cross-organisation communication without creating international data transfers in the legal sense: two EU-based servers communicate with each other, and the data never leaves the EU. For organisations that need to communicate with counterparts in non-adequate countries, the platform supports configurable server-to-server encryption and explicit transfer documentation.
What is the difference between GDPR and UK GDPR for SCOVR deployments?+
The two frameworks are structurally identical. The principal practical differences for a SCOVR deployment are: (1) UK deployments use the ICO as the supervisory authority rather than an EU national DPA; (2) UK-to-third-country transfers require an IDTA or an Addendum to EU SCCs rather than EU SCCs alone; (3) the UK children's data age threshold is 13 rather than 16. All three differences are addressed in the UK-specific variant of the Data Processing Agreement and in the deployment configuration options. EU and UK deployments can run in parallel under the same platform architecture, with data stored separately in each jurisdiction.
How does SCOVR fulfil data subject access requests under Article 15?+
Because all data resides within your own controlled infrastructure, access requests under Art. 15 (and the equivalent UK GDPR provision) can be fulfilled directly by your administrators — without submitting a request to SCOVR and waiting for a vendor response. Administrative tools allow operators to locate, review, and export all personal data for a specific user across all channels and rooms. Erasure requests under Art. 17 are executed definitively — the data exists in one place, and deletion does not depend on a multi-tenant platform's deletion workflows affecting thousands of other customers.
Does the EU Data Act require any changes to how we use SCOVR?+
No. The EU Data Act (Regulation 2023/2854, applicable from 12 September 2025) primarily targets cloud providers that impose vendor lock-in and restrict data portability. Because SCOVR is built on an open standard protocol, cloud switching is a native capability: data can be exported at any time in open formats, migration to a different provider or self-hosted deployment requires no permission, and no switching charges are imposed. The Data Act's prohibition on restrictive contractual clauses (Art. 25) and requirement for structured data portability (Art. 24) are satisfied by the architecture — not by a future product update.

Demonstrate GDPR compliance before day one.

Book a private briefing with our compliance team. We will review your current communications infrastructure against the specific requirements of the EU GDPR and UK GDPR and design a deployment that satisfies them structurally — not through policy alone.

Book a compliance briefing → Download the GDPR guide