Business name of the actor | Role in the hosting service (Host/processor of the Host) | HDS certified | SecNumCloud 3.2 qualified | Hosting activities in which the actor is involved | Access to personal health data from countries outside the European Economic Area, by the Host or one of its processors (Requirement No. 29 of the HDS framework) | Host or processor subject to a risk of access to personal health data from countries outside the European Economic Area, imposed by the legislation of a third country in breach of EU law (Requirement no 30 of the HDS framework) |
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commercetools | Processor | Yes | No | Activities 4 and 5 (HDS v1.1) Activities 3 to 5 (HDS v2.0) | Yes. Support teams may have limited access from the US and other third countries not covered by an adequacy decision. Standard Contractual Clauses (SCCs) are in place. | Yes. United States. Risk mitigated via: SCCs and security controls (see TOMs) Storage-level encryption, with data and encryption keys hosted in the EU. |
MongoDB | Processor | Yes | No | Activities 3 to 5 | Yes. Technical support may access from the US, UK, Canada, India, Australia, Singapore, etc. See the MongoDB HDS-related publication and the certification status. | Yes. United States. The Atlas Control Plane is operated from the US. Risk mitigated via: SCCs and security controls (see Privacy Hub) Data Privacy Framework HDS certification Storage-level encryption, with data and encryption keys hosted in the EU. |
Google GCP | Host | Yes | No | Activities 1 to 6 | Yes. Customer support or telemetry data may be processed from countries such as the US. Data hosting location is customer-configurable. See GCP Data Processing and SCC policies. For more transparency regarding the DSCP processing, see the publication by Google. | Yes. United States. GCP services are subject to US law. Mitigations are in place via: EU SCCs and regionalization options. Data Privacy Framework HDS certification Storage-level encryption, with data and encryption keys hosted in the EU. |