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Hosting data in the United States or the United Kingdom

Note

Work in Progress

Status: first sketch, work in progress, request for collaboration

Date: Updated 2025-04-08

Governance: To Be Discovered; potentially a combo of this repo participants, DHCW CISO, NHS Wales UCB peers, etc.

Context

Our organisation stakeholders are asking questions about hosting data in the United States versus the United Kingdom.

The decision will have significant implications for data security, compliance with legal and regulatory requirements, performance (e.g., latency), cost, risk, piloting, and more.

We want to learn more about how to make a well-informed choice between hosting the data in one of these countries, considering the current needs and potential future growth.

We also want to learn more about hosting in both regions, such as using a multi-cloud approach.

  • We believe there are tradeoffs compliance and operational efficiency.

We also want to learn more about hosting in the EU region, such as using a European hosting company.

  • There may be benefits of EU scale/cost/capabilities over the UK. For example, Germany may offer larger-scale, better-cost, faster-deployment, etc. than the UK.

  • There may be EU law/harmonization/openness as compared to the US. For example, the EU has better legal harmony with the UK relating to GDPR, ISO 27001, etc.

Drivers

We intend to research this area more in depth.

Data Sovereignty and Compliance:

  • U.K.: Hosting in the U.K. offers compliance with the General Data Protection Regulation (GDPR), ensuring data privacy and protection. As the U.K. is no longer part of the EU, there are unique data protection regulations, but they are still aligned with GDPR principles.

  • U.S.: The U.S. follows a more fragmented approach to data privacy and protection regulations, with different states having their own laws (e.g., CCPA in California). U.S. regulations may be less stringent than those in the E.U. and U.K., particularly in areas like consumer rights over data.

International Data Transfers:

  • U.K.: The U.K. provides more certainty for international data transfers, as it follows a similar framework to the EU's GDPR for cross-border data flow. There is also the UK-EU adequacy decision, which means data can be transferred between the U.K. and the EU without needing additional safeguards.

  • U.S.: Data transfers from the EU/UK to the U.S. are subject to stricter scrutiny, and compliance with frameworks like the EU-U.S. Data Privacy Shield (though invalidated in 2020) or Standard Contractual Clauses (SCCs) is required for lawful data transfer. The U.S. may require more legal efforts and complex agreements around data transfer.

Latency and Performance:

  • U.K.: Hosting in the U.K. is ideal if the user base is primarily located in Europe or other parts of the world that have low-latency access to the U.K. data centers. This can result in better response times for users in these regions.

  • U.S.: If the majority of the user base is based in North America, hosting in the U.S. might offer lower latency and better performance for those users.

Cost:

  • U.K.: Hosting in the U.K. may be more expensive due to higher energy costs, data center hosting fees, and regional operational expenses. However, this could be offset by the benefits of regulatory compliance.

  • U.S.: The U.S. is often considered a more affordable location for data hosting due to lower operational costs in many regions (e.g., server hosting, energy, etc.). Certain providers may offer cost-effective hosting options, especially for large-scale operations.

Legal and Political Environment:

  • U.K.: The U.K. offers a stable political environment, though post-Brexit regulations and trade agreements may introduce some uncertainty around data sovereignty.

  • U.S.: The U.S. has a well-established legal framework for technology and data, but its approach to data privacy and government surveillance (e.g., FISA and Patriot Act) may raise concerns, particularly in Europe or with users who prioritize data privacy.

Future Considerations:

  • U.K.: As a key player in the global economy, the U.K. will likely remain a strong choice for hosting for years to come, especially given its alignment with GDPR-like regulations.

  • U.S.: Depending on future political shifts and regulatory changes, hosting in the U.S. might face stricter scrutiny and regulatory changes, particularly for businesses with international customers.

Recommendation - Decision Outcome

TODO

Consequences

We intend to research this area more in depth.

U.K.:

  • Easier to comply with GDPR-like regulations and to transfer data across EU borders.

  • Potentially higher costs due to the region’s operational overhead.

  • Low latency for European users.

U.S.:

  • Potentially cheaper but may require more complex regulatory agreements for international data transfer.

  • Increased latency for European users.

  • More fragmented privacy laws and potential surveillance concerns.