The problem
- Data crosses borders.AEPD fines up to 4% global revenue.
- OpenAI processes in the US.Article 46 transfer mechanisms don't apply.
- Consent is not enough.Your DPO is exposed.
The solution
EU data stays in the EU. By architecture.
Personal data processed within the EU region. No cross-border transfer. GDPR Art. 5, 25 and 32 covered by the infrastructure layer — your DPO gets a technical guarantee, not a vendor promise.
GDPR Art. 17EU AI ActNIS2
GDPR Art. 9(1)
"Processing of personal data revealing racial or ethnic origin, political opinions, religious beliefs, health data or data concerning a natural person's sex life or sexual orientation shall be prohibited."