Compliant Revision Generation Report
Proposal ID: QD-AS-2024-088
Section: 4.2 Data Residency and Sovereignty

1. Analysis Summary
The flagged text in section 4.2 does not meet the specific data residency requirements for financial services clients as mandated by internal policy and external regulations. The primary issue is the lack of a definitive commitment to in-country data storage and processing, which is a critical requirement for Quantum Dynamics.
2. Identified Compliance Gaps

Vague Geographic Scope: The phrase "data centers located across North America and Europe" is non-compliant with POL-SEC-012B, which requires specifying the exact sovereign territory for data hosting for financial clients.
Implicit Violation of FDSA: By not guaranteeing in-country hosting for PII, the text fails to comply with the Financial Data Sovereignty Act.
Insufficient Detail on DR: The disaster recovery strategy implies potential cross-border data replication, which may also violate residency requirements if not properly defined.

3. Referenced Policies and Guidelines

Internal Policy: POL-SEC-012B (Client Data Hosting - Financial Services)
External Regulation: FDSA (Financial Data Sovereignty Act)
Best Practice Document: BP-CloudHosting-FIN-v2.1

4. Proposed Revisions (Ready to Implement)
Below are two compliant alternatives. Option 1 meets the minimum requirements, while Option 2 provides enhanced assurance suitable for a high-value financial client.

OPTION 1: Standard Compliance
This version provides a clear, compliant statement that meets all core requirements.

"Apex Solutions guarantees that all production data, including any Personally Identifiable Information (PII), for the Quantum Dynamics project will be physically stored and processed exclusively within data centers located in the United Kingdom. Our primary hosting facility is in London, with a geographically separate disaster recovery site in Manchester. This configuration ensures full compliance with the Financial Data Sovereignty Act (FDSA) and our internal data governance policies. Data is encrypted both in transit (TLS 1.2+) and at rest (AES-256)."

Rationale:

Explicitly names the country of data residency (United Kingdom).
Specifies primary and DR locations within the required jurisdiction.
Directly references compliance with FDSA.


OPTION 2: Enhanced Assurance
This version adds further contractual clarity on data handling during support and maintenance activities.

"To ensure strict adherence to all regulatory and internal governance standards, Apex Solutions provides a contractual guarantee that all production data for the Quantum Dynamics project, inclusive of all Personally Identifiable Information (PII), will remain resident within the sovereign borders of the United Kingdom at all times. All primary data processing will occur at our London facility (Equinix LD8), with synchronous replication for disaster recovery at our Manchester facility (Equinix MA5). No production data will be moved or accessed from outside the UK, including for maintenance or support, without explicit written consent. All data is encrypted at rest using AES-256 encryption and in transit via TLS 1.2 or higher."

Rationale:

Includes a stronger "contractual guarantee."
Names the specific data center providers for added transparency.
Adds an assurance clause regarding data access for support functions.