White paper on the NIS2 Act
How to Achieve GDPR Compliance in a Hybrid Cloud Environment
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Das wichtigste auf einen Blick
- Hybrid cloud models combine on-premises systems and public cloud services – creating new GDPR challenges.
- Data protection remains your responsibility, even when cloud providers host your data.
- Encryption, access management, and data processing agreements are mandatory.
- Automated monitoring ensures transparency and continuous compliance.
- With heyData, you can centrally manage and document GDPR compliance in the cloud.
Introduction
The cloud has become standard – but very few companies rely on it exclusively.
In practice, sensitive data is often processed both locally (on-premises) and in cloud services. This hybrid cloud model offers many benefits, but also poses serious data protection risks.
The GDPR is clear on this point:
Even when you use services from Amazon, Microsoft, or Google, your company remains responsible for protecting personal data.
In this article, you’ll learn:
- which GDPR obligations apply in a hybrid cloud,
- how to implement technical and organizational measures,
- and how heyData helps you automate processes and document compliance.
Table of Contents:
What is a hybrid cloud – and why does it matter for GDPR?
A hybrid cloud combines private IT systems (e.g. in-house servers) with public cloud services such as AWS, Azure, or Google Cloud.
Benefits
- Scalability during peak loads
- Lower costs through outsourced infrastructure
- High flexibility for applications
The challenge
Data moves between systems, locations, and providers.
This increases data protection risks – especially when international data transfers and multiple parties are involved.
White paper on the NIS2 Act
GDPR obligations in a hybrid cloud
a) Responsibility remains with your company
Under Article 24 GDPR, your organization remains the data controller – even if cloud providers process data on your behalf.
You must ensure that all providers act in a GDPR-compliant manner.
b) Data processing agreements (Article 28 GDPR)
You must conclude a data processing agreement (DPA) with every cloud provider.
These agreements must regulate:
- categories of personal data
- purposes of processing
- technical and organizational measures (e.g. encryption, access controls)
- data storage locations (EU / third countries)
- audit and inspection rights
c) Data transfers to third countries
If data is processed or stored outside the EEA (e.g. in the US), you need:
- Standard Contractual Clauses (SCCs) or
- other appropriate safeguards, such as the EU–US Data Privacy Framework.
The biggest GDPR risks in hybrid cloud environments
| Risk | Description | Mitigation |
|---|---|---|
| Uncontrolled data flows | Data stored in cloud apps without central oversight | Data inventory & classification |
| Unclear responsibilities | No clear owner for data protection | Defined governance structure |
| Lack of transparency | Unknown data storage locations | Providers with EU data centers |
| Security gaps | Open interfaces or unencrypted backups | Encryption & access restrictions |
| Third-party compliance failures | Missing DPAs or unchecked subprocessors | Due diligence & audits |
Step-by-step guide to GDPR-compliant hybrid clouds
Step 1: Create a data inventory
- Identify all systems, storage locations, and applications
- Document where personal data is processed
- Use data mapping tools or heyData to maintain oversight
Step 2: Conduct a Data Protection Impact Assessment (DPIA)
A DPIA under Article 35 GDPR is mandatory for high-risk processing, such as:
- health data
- AI-based systems
Assess:
- level of risk
- protective measures
- technical security standards
Step 3: Review contracts and internal policies
- Ensure valid DPAs with all cloud providers
- Verify and contractually secure subprocessors
- Update internal policies on data storage, backups, and deletion
Step 4: Implement security measures
- Encrypt data in transit and at rest
- Apply the least-privilege principle
- Enable multi-factor authentication
- Perform regular penetration tests
Step 5: Establish continuous monitoring
Hybrid cloud compliance is not a one-time project.
Rely on automated monitoring:
- real-time alerts for new data transfers
- automated audit reports
- notifications of unauthorized access
heyData provides:
- continuous risk monitoring
- DPA management
- GDPR reporting with audit-ready documentation
Technical best practices
| Area | Measure | Benefit |
|---|---|---|
| Data encryption | AES-256, TLS 1.3 | Protection in transit and at rest |
| Identity management | MFA, role-based access | Prevents misuse |
| Backup & recovery | Geo-redundant storage | Ensures availability |
| Logging & auditing | Centralized logs, SIEM | Transparency & traceability |
| Network security | Firewalls, VPN, Zero Trust | Reduced attack surface |
Common mistakes to avoid
- Blind trust in cloud providers
- No overview of subprocessors
- Outdated contracts or certifications
- Lack of centralized monitoring
- Manual documentation that is slow and error-prone
Benefits of automated GDPR compliance
- Time savings: Reports and DPIAs generated automatically
- Transparency: Dashboards visualize data flows and risks
- Audit readiness: All measures documented in an audit-proof way
- Early warning system: Real-time detection of compliance issues
- Legal certainty: DPAs, SCCs, and DPIAs centrally managed
Looking ahead: Multi-cloud and AI systems
The next challenge:
Companies increasingly use multiple cloud providers (multi-cloud) and AI systems based on cloud data.
This means:
- more data flows
- more data processors
- higher requirements for documentation, proof, and technical controls
Automated compliance platforms like heyData become essential – combining data protection, audits, training, and risk analysis in one system.
FAQs about GDPR in the hybrid cloud
What is a hybrid cloud?
A hybrid cloud combines on-premises servers with cloud services. Data is stored partly internally and partly externally.
Does GDPR apply to cloud providers?
Yes. Cloud providers act as data processors, but responsibility always remains with your company.
What do I need for GDPR compliance in the cloud?
DPAs, transparency about data locations, technical safeguards, and documented proof of security measures.
How can I protect data in the cloud?
Through encryption, access controls, regular audits, and continuous monitoring.
How does heyData help?
heyData automates data protection checks, DPAs, monitoring, and reporting – specifically for hybrid and multi-cloud environments.
Important: The content of this article is for informational purposes only and does not constitute legal advice. The information provided here is no substitute for personalized legal advice from a data protection officer or an attorney. We do not guarantee that the information provided is up to date, complete, or accurate. Any actions taken on the basis of the information contained in this article are at your own risk. We recommend that you always consult a data protection officer or an attorney with any legal questions or problems.