Privedge The laws. The articles. The solution.
Article-by-article regulatory analysis
This document contains the technical-legal analysis of how the Privedge architecture satisfies the concrete requirements of each regulation. Each article includes the requirement text and the technical control that covers it. Designed for DPOs, CISOs, and legal teams.
A dataset is considered de-identified if the 18 identifiers are removed: names, dates, phone numbers, emails, SSN, MRN, account numbers, etc.
Privedge detects and redacts exactly those identifiers (names via NER; SSN, MRN, dates, phone, email via regex) before the prompt leaves the node. The payload meets Safe Harbor.
Use or disclosure of PHI must be limited to the minimum necessary for the purpose.
Edge mode removes disclosure entirely: PHI is never disclosed to a third party because inference happens on the node.
Sharing PHI with a provider (OpenAI) requires a signed BAA.
If OpenAI never receives PHI, there is no business associate relationship to document. The AI provider falls outside the HIPAA perimeter.
Any breach of unencrypted PHI requires notifying affected parties and HHS within strict deadlines.
A breach at the AI provider does not expose PHI: it only saw tokens. The risk of mandatory notification drops drastically.
The controller must apply appropriate technical measures, including the pseudonymization and encryption of personal data.
Privedge's reversible pseudonymization literally is the measure Art. 32(1)(a) asks for. You don't "comply with" it: your architecture implements it.
Privacy must be built into the architecture, not bolted on as policy.
The edge as anonymization point is privacy-by-design in its purest form: data cannot leak because it never leaves the node.
After the Privacy Shield was struck down, transferring to the US requires SCCs + supplementary technical measures.
If only anonymized data leaves, there is no transfer of personal data (Recital 26). SCCs and the Transfer Impact Assessment are eliminated for the AI call.
The GDPR does not apply to anonymous information that does not allow identifying a person.
The payload reaching OpenAI falls outside the material scope of the GDPR. This is the central legal argument of Privedge.
The processor must offer sufficient guarantees and operate under contract.
Privedge acts as a processor under a DPA. The triangle stays clean: client (controller) → Privedge (processor) → AI (out of scope, only sees tokens).
Any personal data breach must be reported to the authority within 72h.
A breach at the AI provider only exposes tokens. If there is no personal data breach, the Art. 33/34 obligation is not triggered.
The card number (PAN) must be rendered unreadable via truncation, tokenization, or encryption.
Privedge tokenizes the PAN before the prompt leaves. The cloud never receives the real card number.
Tokenization reduces the PCI audit scope of systems that no longer store real PAN.
By never sending real PAN to the AI provider, that flow leaves PCI scope. Fewer systems to audit = a cheaper audit.
Deidentified information is excluded from the definition of "personal information".
The anonymized payload reaching the AI is deidentified information: outside the scope of CCPA/CPRA.
CPRA created the SPI category (SSN, geolocation, health, financial data) with a reinforced regime.
Privedge detects and redacts SPI before any third-party processing.
Anonymized data is not considered personal data unless the anonymization process can be reversed with reasonable effort.
The data leaving the node is anonymized; the reversal map never leaves the boundary. Outside the LGPD scope for the third party.
International transfer requires an adequate country or specific guarantees approved by the ANPD.
With no personal data in the payload, there is no international transfer of personal data to authorize.
New control in the 2022 revision: data masking to limit exposure of sensitive information.
Privedge implements data masking in the AI flow as a direct, demonstrable technical control for the auditor.
Data leakage prevention measures applied to systems that process sensitive information.
The proxy is exactly a DLP control on the AI channel: it detects and blocks the leakage of PII and secrets (API keys, JWTs).
Confidential information must be identified and protected throughout its lifecycle.
Privedge identifies PII in real time and prevents its disclosure to subprocessors. The dashboard documents every detection.
Collection, use, retention, and disclosure of personal information in line with the entity's commitments.
Privedge's logs —what PII, what strategy, what node, what latency— are the evidence the SOC 2 auditor asks for.
High-risk AI systems must apply data governance practices with minimization and safeguards.
Privedge is the data governance layer at the entrance of the AI system: it controls what personal data is processed and how it is minimized.
High-risk systems must automatically log events to ensure traceability.
Privedge's dashboard logs every request, detection, and applied strategy: traceability ready for the AI Act technical file.
Secondary use of health data requires secure processing environments and anonymized or pseudonymized data.
Privedge's edge architecture is exactly what the EHDS demands: clinical data is anonymized on the node or never leaves it.
Using external ICT providers (an AI provider) requires assessing and mitigating concentration risk.
By not sending identifiable data to the AI provider, the ICT third-party risk drops drastically: their compromise does not expose client data.
| Certification | Status | Provider | Scope |
|---|---|---|---|
| SOC 2 Type II | Active | Cloudflare, Inc. | Compute, network, data center operations |
| ISO 27001:2022 | Active | Cloudflare, Inc. | Information security management |
| HIPAA-eligible | Active | Cloudflare Workers | PHI processing on Cloudflare infrastructure |
| PCI DSS Level 1 | Active | Cloudflare, Inc. | Network infrastructure |
| SOC 2 Type II | Roadmap (2026) | Privedge | Application-level controls |
- PII detection and tokenization in every prompt
- Token maps never written to persistent storage
- TLS 1.3 for all data in transit
- V8 isolate per request — zero cross-request state
- Audit metadata logging (no prompt content, no PII values)
- Breach notification to Customer within 24 h of discovery
- Deletion of all retained data within 30 days of contract end
- Determining applicable regulations for their industry
- Configuring detection profiles for their data types
- Conducting their own DPIA / ISMS assessment
- Handling data subject requests from their users
- Compliance of their application layer and user interface
- Regulatory filings and engagement with supervisory authorities
- Ensuring their users do not deliberately encode PII as tokens
Note: Privedge does not provide legal advice. Customers must engage their own legal counsel to determine the adequacy of these controls for their specific regulatory obligations.
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