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Data residency and privacy - deployment-dependent facts

Privacy and data residency outcomes depend on where AIS runs, which subprocessors are in scope, and what categories of data your channels send. This page states facts at the right level of generality and flags depends on deployment everywhere it matters.

Roles: controller vs processor (conceptual)​

  • Your bank is typically the controller for customer relationship data you choose to send into AIS-backed workflows.
  • AIS (or an affiliate named in your agreement) may act as a processor or service provider, only as defined in your contract-not determined by this website.

Action: have privacy / legal align contract roles with local law (labels differ by jurisdiction).

Data categories and minimization​

Banks usually classify data (for example direct identifiers, financial attributes, bureau references). AIS implementations should only process what is needed for the credit decision or workflow you purchased-exact fields are in your data specification, not here.

:::caution Consent and lawful basis

Lawful basis, consent text, and cross-border transfers are bank decisions with counsel. AIS can describe technical mechanisms (for example encryption in transit); legal adequacy is outside this portal.

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Residency and cross-border processing​

Whether data stays in a specific country or region is determined by hosting choices and subprocessors in your deployment. Some banks require dedicated environments; others use shared multi-tenant platforms with logical isolation.

You should obtain in writing (from AIS):

  • Primary processing and storage locations for production and non-production.
  • Whether administrative access from AIS staff can cross borders (support model).
  • Whether backups and logs share the same residency posture as primary databases.

If any item is unknown, record it as a finding until the DPA or security annex closes it.

Retention and deletion​

Retention of scores, decisions, documents, and logs should be contractual and aligned to your retention schedule. Deletion and return of data at exit are deal points-do not infer them from marketing pages.

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