Quickstart: Automate European Privacy

Review the DPA, enable strict mode, capture consent, configure residency, execute erasure cascade, monitor compliance — the full implementation in 6 steps, in under 30 minutes.

1

Review the Data Processing Agreement

GDPR ArticleWhat it requiresAeion's technical control
Art. 28Processor obligations + sub-processor listAllowlisted AI providers + sub-processor registry
Art. 32(1a)Pseudonymisation + encryptionAES-256-GCM at rest, TLS 1.3 in transit
Art. 32(1b)Confidentiality + integrityHMAC-SHA256 audit log signing, immutable storage
Art. 32(1c)Restore availability after incidentAegis backup + PITR + time-travel
Art. 32(1d)Regular testing of effectivenessBackup verification + penetration test program
Art. 17Right to erasureAutomated purge-and-anonymization cascade
Art. 20Data portabilityFull data export in machine-readable JSON / CSV
Art. 30Records of processing activitiesAudit log + processing activity registry
Art. 33Breach notification (72 hours)Incident-response runbook + auto-notification workflow
2

Enable the gdpr-strict Compliance Profile

Navigate to Admin → Compliance → Profile and set the tenant compliance profile to gdpr-strict.

What strict mode enforces (automatically):

  • Data residency — at boot, the kernel reads the cloud region. If outside the EU (or your configured allowlist), critical operations are blocked.
  • AI provider gating — non-BAA / non-EU AI providers blocked at the gateway. Only allowlisted EU-region providers can process PHI / PII.
  • Cross-border transfer policy — outbound API calls to non-EU endpoints automatically refused unless explicitly allowlisted with documented legal basis (SCC + DPF certification).
  • Retention policy locks — minimum retention enforced per record type (consent records: 7 years; transcripts: 30 days; recordings: 30 days).
  • Encryption mandatory — at-rest + in-transit; weak ciphers (TLS < 1.3, AES-128 in transit) refused.
  • Pseudonymisation defaults — new PII fields require either encryption or explicit "pseudonymisable" tag.

Compliance profile is set per-session (Realtime sessions, transcription jobs, AI invocations) and inherited from the tenant default. Configure the tenant default in Admin → Compliance → Profile; per-session overrides happen when the session is created (each module documents the profile field on its session/job creation route).

typescript // Per-session profile override — Realtime example await aeion.api.post("/api/realtime/sessions", { /* ... other session fields ... */ complianceProfile: "gdpr-strict", });

Mode switch is one-way for production safety. Once gdpr-strict is enabled, you can't accidentally downgrade. Switch back requires support ticket + audit log entry.

3

Capture Explicit Consent

SurfaceWhat it captures
**Onboarding modal**Account creation T&Cs + Marketing opt-in + Cookies
**Pre-feature modal**Specific feature consent (e.g., "Allow AI transcription")
**Per-channel opt-in**Email / SMS / phone marketing separately
**Cookie banner**Granular cookie category opt-in (GDPR Cookie Directive)
**Per-session modal**Recording consent before video session starts
4

Configure Data Residency

Beyond the strict profile, configure granular residency rules.

Region pinning is configured at the tenant level via the platform deployment topology (Admin → Platform → Tenant Settings → Residency) and enforced by the kernel at boot. Region claims propagate via the compliance profile — when a tenant runs gdpr-strict, the kernel refuses operations that would cross the configured residency boundary.

Per-record residency overrides — for high-sensitivity records (medical, financial), configure to never cross regions even within the EU.

Auto-replication policy:

  • Backups stay in-region (BYOB S3 in EU regions for EU tenants)
  • Disaster recovery requires explicit cross-region setup (signed off by your DPO)
  • Audit trail logs every cross-region operation

Per-feature residency override:

  • Some features (e.g., voice transcription) may need a specific provider not available in all regions
  • Per-feature residency policy: "Aeion AI gateway: route to azure-openai-eu only"
  • If the configured provider has an outage, the feature degrades gracefully (returns to deterministic fallback) rather than secretly routing to a non-EU provider
5

Execute the Right-to-Erasure Cascade

When a data subject invokes their Article 17 right, do not write custom SQL scripts. Use the built-in erasure cascade.

Cascade workflow:

  1. Receive the request — email, web form, support ticket, or data subject portal
  2. Verify identity — confirm the requester is the data subject (typically via email re-verification + secondary identifier)
  3. Trigger the cascade — Admin → Privacy → Erasure Requests → New → User ID → Execute
  4. Cascade runs — 5-stage execution across all modules:
  5. Receipt delivered — to data subject + audit log + your DPO

Aggregate data preserved: the cascade uses "in-place redaction" — PII deleted but record skeletons preserved so your financial dashboards + product analytics stay accurate.

Automating erasure at scale: for high-volume tenants that need to trigger erasure programmatically (rather than one request at a time via the Admin UI), the erasure endpoint accepts the same request shape as the manual flow — target user, reason, and the authorizing operator — and returns a cascade trace with per-collection redaction counts. Realtime and other modules listen for the resulting erasure event and run their own redactors automatically, so you don't have to coordinate module-by-module cleanup yourself.

Sub-60-second execution for typical tenants. Even 5M+ row tenants complete in under 5 minutes.

6

Monitor Compliance Reporting

Compliance isn't one-and-done. Monitor continuously.

Quarterly compliance reports:

  • Auto-generated PDF + JSON every quarter
  • Sent to your DPO + legal counsel
  • Available in Admin → Compliance → Reports

Report contents:

  • GDPR control effectiveness — every control category with evidence
  • Erasure request stats — count, average resolution time, exceptions
  • Consent metrics — capture rates, withdrawal rates, conversion impact
  • Sub-processor changes — any new/removed sub-processors (Art. 28(2))
  • Breach incidents — zero target; any incidents with response timeline
  • Cross-border transfers — any transfers + legal basis documented
  • Data residency proof — quarterly attestation of data location

Real-time alerts:

  • Configurable thresholds — alert if erasure request takes > 30 days, alert on first cross-border transfer attempt, alert on consent withdrawal rate spike
  • Routes to your DPO + relevant module owners
  • Auto-creates Helpdesk tickets for high-severity items

Audit-ready evidence:

  • One-click export of any time range for ICO / CNIL / supervisory-authority requests
  • Cryptographically signed evidence package (HMAC-SHA256 with rotated keys)
  • Machine-readable JSON + human-readable PDF in same package

Integration Recipes

Realtime sessions → GDPR-strict mode. Set compliance: "gdpr-strict" when creating a Realtime session. The platform automatically enforces consent capture before AI transcription, restricts to EU AI providers, and applies retention policies to recordings.

Marketing campaigns → consent gating. Marketing module reads consent records before sending campaigns. A customer who opted out of marketing automatically excluded; consent expiry (7 years for explicit, 2 years for soft opt-in) tracked.

CRM segment-driven retention. Different customer segments may have different retention policies (B2B contacts vs B2C prospects). Configure per-segment retention rules; cascade respects them.

Aegis backup residency. Backups inherit the tenant's data-residency settings. EU tenant backups go to EU S3 buckets (Cloudflare R2 EU, AWS S3 eu-west-1, etc.) — never US-based storage unless explicitly allowlisted with documented SCC.

Forge audit + ADR linkage. When data-processing decisions are made (new AI provider, new sub-processor, retention policy changes), they log as ADRs in Forge with timestamps + signing officer. Auditor-ready.

Sentinel monitoring. Sentinel watches for suspicious patterns — multiple PII access from same user in short window, mass-erasure attempts, unusual export volume. Surfaces to security team via the rule engine.

Troubleshooting

gdpr-strict mode is blocking a feature I need. Check Admin → Compliance → Profile → Blocked Operations. The blocked feature will show its reason (provider not allowlisted, region not allowed, retention conflict). Resolve by either: (1) reconfiguring the feature for compliance, (2) adding an explicit exception with documented legal basis.

Erasure cascade taking unusually long. Common cause: a module with large historical data (e.g., 10M+ marketing events). Check Admin → Compliance → Erasure → [request] → Stage Status. The stage-by-stage view shows where time is being spent. Switch to async cascade for very-large erasures.

Consent record disputed by user. The audit log shows the exact consent text + version + capture context. If the user disputes it, the record stands as primary evidence. If dispute escalates, the cryptographic signing + immutable storage provide tamper-evidence for court use.

Cross-border transfer attempted unexpectedly. Investigate via Admin → Compliance → Cross-Border Log. Common causes: (1) module attempting non-allowlisted external API, (2) sub-processor introduced via dependency update. Block via the profile config + investigate the upstream cause.

Audit log integrity check failed. Critical alert — investigate immediately. Possible cause: storage corruption, intentional tampering, or signing-key rotation issue. The forensic mode shows which rows have integrity violations + when they happened.

Erasure cascade partial completion. If a stage fails, the cascade pauses and surfaces the failure. Resume via Admin → Compliance → Erasure → [request] → Resume. The remaining stages execute. Most common cause: external system (third-party CRM, etc.) unavailable.

Frequently Asked Questions

By default, no. The profile blocks cross-border data egress. However, if you execute Standard Contractual Clauses (SCC) + verify the provider's EU-US Data Privacy Framework (DPF) certification, an Admin can override the allowlist in tenant config to permit specific US sub-processors. Documented legal basis required.

Metrics remain accurate. The erasure cascade uses "in-place redaction" — deletes PII (name, email) but preserves aggregate rows (token usage, transaction amounts) so billing + analytics dashboards continue working.

Under gdpr-strict, default retention window is 30 days. Background cron hard-deletes recordings older than 30 days unless a Legal Hold has been explicitly applied. Recordings tied to ongoing litigation can be held indefinitely.

Yes — Incident Response runbook surfaces an unresolved security incident as a 72-hour countdown timer. If your tenant's DPO doesn't acknowledge by hour 24, a "still open" reminder escalates to your incident-response channel. By hour 60, a draft breach notification is auto-prepared for your DPO to review + send.

Yes. Admin → Privacy → Portability Requests → New. The Portability service exports all of a user's data in machine-readable JSON / CSV with full provenance metadata. Customer-uploadable to another GDPR-compliant service.

Overlapping but not identical. CCPA / CPRA (California) and similar US state laws have different scope, definitions, and rights. Aeion's compliance profile supports each: `gdpr-strict`, `ccpa`, `lgpd` (Brazil), `pdpa` (Singapore). Stack profiles if you serve multiple jurisdictions.

Sub-processor registry in Admin → Compliance → Sub-Processors. Every entity that touches PII is registered with role, region, legal basis, and Aeion's contractual relationship. Updates require admin approval + DPO notification. Audit-ready for ICO / CNIL requests.

Yes — via Singularity connectors. Bidirectional sync of consent records, breach incidents, data-subject requests. Use Aeion's native tooling for the technical execution + the privacy tool for board reporting.

Significantly lower than custom systems. Aeion's audit-ready evidence + immutable signed audit log + automated controls dramatically reduce audit preparation time. Production deployments report 5-10x faster audit cycles vs custom-built systems.

Aeion's documentation covers operational procedures. For compliance-specific training (DPO certifications, ICO best practices), partner with specialized providers. Aeion can integrate with LMS / training-tracking systems via the LMS module.

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