These matters of complicated jurisdiction and sovereignty law require the advice of an experienced international lawyer. These lawyers need the advice of experienced international technologists, and that is the bit I do. Each has to know quite a bit about what the other is doing, so I study the relevant statutes and speak to the people who are drafting the next versions of the regulations.
The 2023 EU-US Data Privacy Framework (DPF) ↗ was intended to put limits on US surveillance of EU citizens (with UK citizens covered in a later bolt-on) but in 2026 it is on life support. Designed to allow US companies such as Amazon, Microsoft, Iron Mountain and the like to hold vast amounts data despite US government spying, it has had mandatory parts of it collapse. The US Privacy and Civil Liberties Oversight Board (PCLOB) is one, and the equally essential US Act of Congress FISA Section 702 ↗ expired in June 2026. These failures do not stop the surveillance, just the oversight of the spying the US promised. EU/UK businesses often choose to store their data within US control, and so these laws and frameworks are designed to make it legal for them to do so. See the companion article on the root cause, but the upshot is there is no protection for EU/UK data. These legalities are a kind of expensive compliance dance that does not achieve its goal, except to continue the revenue stream for these US companies.
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