In this paper, we analyse the results of a detailed survey of the privacy policies, and data protection terms more broadly, of 40 major cloud computing services, including Amazon Web Services, Google Cloud, and Microsoft Azure. We review terms relating to controller and processor designations;...

Effective protection of individuals under the EU’s General Data Protection Regulation (‘GDPR’) depends mainly on the ‘accountability’ of one or more persons, usually organizations, for ensuring compliance with relevant obligations. As we will see, identifying the ‘controllers’,...

In this paper we explore the rights that individuals have under the EU’s General Data Protection Regulation (‘GDPR’) when their data are processed in clouds, and the remedies that might be available to them if those rights are breached. The complex nature of cloud ecosystems can make it...

There has been on-going discussion regarding the alignment of cloud computing services to a range of European policy objectives. This paper provides an outline of key legal and regulatory aspects arising from recent calls for establishing a Europe-only cloud. After covering the background to...

Where data centres located in the European Economic Area ('EEA') are utilised for cloud computing services, the customers, and in some circumstances even cloud service providers, could become subject to the EU Data Protection Directive on the basis that the data centre may be an...

Cloud computing service providers, even those based outside Europe, may become subject to the EU Data Protection Directive's extensive and complex regime purely through their customers' choices, of which they may have no knowledge or control. We consider the definition and application of the EU...

In part one of this series, we considered what information is regulated as 'personal data' in the cloud. In this part two, we develop further the argument made in part one that it is not appropriate for infrastructure cloud providers, many of which are based outside Europe, to become subject...

This paper explores the extent to which public cloud computing is in fact being used in practice by banks operating in the EU, including global banks. It is based primarily on anonymised interviews with banks, cloud providers, advisers, and financial services regulators. This paper describes how...