| If you are sending a message to a person in another country, you are consenting to that communication traveling to the location of that person. See article 6: 1. Processing shall be lawful only if and to the extent that at least one of the following applies: (a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes; (b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract [.. other permissible purposes snipped ..] Generally, the GDPR issues with sending to another country boil down to whether the EU accepts that the other country's government will allow the company protect the data in ways compatible with the GDPR. When sending that data to another company happens for reasons incidental to the permissible purpose of your data (eg EU-to-EU data processed in the US) this becomes an issue, as you've not consented to that risk. If you are specifically requesting that your data be sent to, say, the US, however, then processing that data in the US becomes necessary and thus much more justified. From a technical perspective, you can certainly silo your data and transfer only as needed. This is however way more complicated, as you need to now deal with the fact that you're potentially performing joins across high-latency datastores, where you might need to be careful about what query data you're sending across the wire, and where your different silos need to apply access controls against each other. If you didn't engineer for this from the start, it's a big shift in architecture. |