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EU Data Act Informational Disclosures (Articles 26 & 28)

Data Portability & Hosting Transparency

Verified technical specifications, provider switching processes, infrastructure jurisdiction, and defense-in-depth safeguards against unlawful governmental access for customer data processed by TeamGRC.

Content Reviewed & Last Updated: September 19, 2026
Primary Hosting Location: AWS Europe (Frankfurt)
Legal Jurisdiction: The Netherlands (Amsterdam District Court)

Data Portability and Provider Switching

TeamGRC is engineered to empower customer data sovereignty through comprehensive, self-service audit deliverables. At the conclusion of a customer agreement or during provider switching, the data that the customer can receive and export consists strictly and exclusively of the reports they create themselves from the platform's Audit section. It is entirely up to the customer to generate these reports and download them prior to account termination.

Customer Responsibility & Self-Service Report Export
Under Sections 10.1 and 11.2 of the TeamGRC Master Services Agreement (MSA), customers retain exclusive ownership of all compiled governance deliverables, readiness reports, and policy documents. TeamGRC guarantees a 30-day Data Export Window post-termination. During this window (and throughout active subscription), it is entirely up to the customer to create the reports and download them directly from the Audit section of the platform. TeamGRC does not perform manual backend database dumps, raw table extractions, or vendor-side offboarding data pulls.

Scope of Exportable Audit Reports

The data eligible for export and portability is limited strictly to the compiled, auditor-ready PDF deliverables that customers generate on-demand within the platform's Audit section:

Custom Audit Evidence Packages

Assembled on-demand via Generate Custom Audit Report across 9 modular packages: Scope & Responsibilities, Risk & Posture, Regulations Matrix, Standards Matrix, NIST CSF - Core, NIST CSF - Target Profiles, ISO/IEC 27001, Policies & Controls, and Executive Oversight.

ISO 27001 Stage 1 Readiness Report

Generated via Generate ISO 27001 Stage 1 Report to verify implementation of core ISMS clauses, prerequisite checks, and organizational scoping for external certification body audits.

Audit Reports Registry & Meeting Minutes

Accessed and downloaded from Audit Reports, including historically compiled audit packages, regulatory matrices, and signed Clause 9.3 Management Review meeting minutes with SHA-256 cryptographic verification hashes.

Approved Policy Documents Export

Exported as immutable PDF documents via Policy Documents Export across all five GRC pillars (Governance, Data & Privacy, Engineering & Operations, Ecosystem & People, Resilience), including operative requirements and approval sign-offs.

How Customers Generate and Download Reports

Report generation and data extraction at TeamGRC is 100% self-service. Customers create and download each report directly through the native UI in the Audit section:

  • Custom Audit Report Compilation: In the platform sidebar, navigate to Audit > Generate Custom Audit Report. Select individual packages or click "Choose All", verify prerequisite completion, and click Generate Selected Reports. The compilation engine automatically aggregates the data and generates corresponding PDF reports (taking approximately 10–30 seconds per report).
  • ISO 27001 Stage 1 Report Generation: Navigate to Audit > Generate ISO 27001 Stage 1 Report. Verify that ISMS prerequisites are met, then click Generate Stage 1 Report to produce the comprehensive external auditor readiness package.
  • Audit Registry & Meeting Minutes Downloads: Navigate to Audit > Audit reports. The registry provides immediate access to view and download previously compiled audit packages, regulatory matrices, and signed Clause 9.3 Management Review meeting records in PDF format.
  • Approved Policy Documents Download: Navigate to Audit > Policy Documents Export. Download individual or bundled approved organizational policies as PDF documents for local archival or offline inspection.
  • Customer Sole Responsibility: Generating and downloading these deliverables is strictly the customer’s responsibility. TeamGRC does not provide manual backend database extractions, raw API dumps, or engineering offboarding extraction services. Customers must ensure all required reports are generated and downloaded before their subscription access or post-termination export window expires.

Step-by-Step Provider Switching Protocol

To transition compliance records seamlessly from TeamGRC to another GRC platform or internal corporate archives, follow this customer-driven self-service workflow:

1
Generate Custom Audit Evidence Packages
Navigate to Audit > Generate Custom Audit Report. Select all relevant packages (Scope & Responsibilities, Risk & Posture, Regulations, Standards, NIST CSF Core, Target Profiles, ISO 27001, Policies & Controls, Executive Oversight) and click "Generate Selected Reports" to compile standardized PDF reports.
2
Generate ISO 27001 Stage 1 Readiness Report
Navigate to Audit > Generate ISO 27001 Stage 1 Report. Verify that mandatory ISMS prerequisites are satisfied, then trigger generation to compile the comprehensive Stage 1 certification readiness binder.
3
Download Historical Audit Reports & Review Minutes
Navigate to Audit > Audit reports to download all previously compiled audit reports, regulatory matrices, and signed ISO Clause 9.3 Management Review meeting minutes with cryptographic SHA-256 checksums.
4
Export Approved Policy Documents
Navigate to Audit > Policy Documents Export and download all finalized corporate operational policies across all five GRC pillars in immutable PDF format.
5
Archive Locally & Execute Post-Termination Data Erasure (MSA §19.2)
Store all downloaded PDF deliverables in your organization’s long-term compliance repository. Following the 30-day Data Export Window (or earlier upon customer written notice), TeamGRC permanently deletes and purges all live database records, tenant configurations, and objects storage partitions. Residual disaster recovery backups roll off and are permanently overwritten in accordance with TeamGRC’s 90-day backup lifecycle.

Report Formats, Technical Boundaries & Realistic Switching Expectations

Export Deliverables Are Document-Based (PDF)
Customer exportable data at the end of the subscription consists strictly of the compiled, audit-ready PDF reports and policy documents created by the customer in the Audit section, rather than raw database dumps, JSON database schemas, or relational database table extracts.
  • Standardized Document Deliverables: Exports are delivered as standardized, auditor-ready PDF documents. They encapsulate complete policy text, risk matrices, control mappings, and management review decisions. Migrating to another GRC tool entails ingesting these structured PDF deliverables; raw relational foreign keys and database schemas are not exported.
  • Customer-Driven Pre-Termination Requirement: Because all audit reports are generated on-demand by the customer within the active application UI, reports cannot be compiled after tenant account closure. It is the customer's sole responsibility to generate and download all desired reports prior to the end of their subscription or export window.
  • Tenant Settings & Access ACLs: Internal platform user profiles, role definitions, MFA tokens, session logs, and tenant UI preferences are specific to the TeamGRC SaaS platform and are non-transferable.

Distinction: Customer Deliverables vs. TeamGRC Proprietary Platform

In accordance with Sections 10 and 11 of the Master Services Agreement, the legal and operational boundaries between customer deliverables and vendor intellectual property are defined as follows:

Data Category Included Items Legal Ownership & Portability
Customer-Owned Reports & Deliverables All audit evidence packages, ISO 27001 Stage 1 readiness reports, approved policy documents, risk registers, and signed management review minutes generated and downloaded by the customer from the Audit section. Exclusively Owned by Customer
Full export rights at no cost; perpetual right to use, modify, archive, and present to external auditors and regulators.
TeamGRC Proprietary Platform & Engine Platform source code, report compilation engine, AWS serverless architectures, AgentCore / Bedrock AI prompts and orchestration workflows, proprietary risk scoring ontologies, baseline benchmark questionnaire definitions, and UI workflows. Retained Exclusively by TeamGRC
Proprietary vendor intellectual property; not subject to customer export or third-party licensing.

Maintainable Audit Reports Register

The register below catalogs the verified customer-exportable deliverables created and downloaded through the Audit section, their file formats, application navigation source, preserved fields, and integrity standards:

Report Deliverable Export Format Audit Section Source Preserved Fields & Relationships Standards & Integrity
Custom Audit Evidence Packages PDF (PDF/A) Audit > Generate Custom Audit Report 9 selectable modular packages: Scope & Responsibilities, Risk & Posture, Regulations Matrix, Standards Matrix, NIST CSF (Core & Target Profiles), ISO/IEC 27001, Policies & Controls, and Executive Oversight. Assembles scope boundaries, threat likelihood/impact ratings, regulatory cross-walks, and control mappings. ISO 19005 (PDF/A), FIPS 180-4 (SHA-256)
ISO 27001 Stage 1 Readiness Report PDF (PDF/A) Audit > Generate ISO 27001 Stage 1 Report ISMS implementation evidence across mandatory Clauses 4–10, prerequisite verification checklists, Statement of Applicability status, and formal auditor readiness declarations. ISO/IEC 27001:2022 Stage 1 Criteria, PDF/A
Audit Reports Registry & Meeting Minutes PDF (PDF/A) Audit > Audit reports Historically compiled audit evidence packages, regulatory matrix snapshots, and signed Clause 9.3 Management Review meeting minutes including attendee records, strategic decisions, and embedded document verification hashes. ISO 27001 Clause 9.3, FIPS 180-4 (SHA-256 Checksums)
Approved Corporate Policy Documents PDF (PDF/A) Audit > Policy Documents Export Versioned operational policies across all five GRC pillars (Governance, Data & Privacy, Engineering & Operations, Ecosystem & People, Resilience), operative requirements, control links, and approval sign-off metadata. ISO 19005 (PDF/A)

Audit Section Report Package Specifications

The platform's Audit section compiles your organization’s operational and compliance data into four standardized, immutable report categories. These report packages provide comprehensive, auditor-ready documentation for provider switching, external certification, and regulatory inspection:

Custom Audit Evidence Packages (Audit > Generate Custom Audit Report)
On-demand compilation engine covering 9 selectable modules: Scope & Responsibilities, Risk & Posture, Regulations, Standards, NIST CSF Core, Target Profiles, ISO 27001, Policies & Controls, and Executive Oversight.
9 Selectable Packages (PDF)
ISO 27001 Stage 1 Readiness Audit Binder (Audit > Generate ISO 27001 Stage 1 Report)
Comprehensive external auditor readiness report verifying ISMS prerequisite checklist items, core clause coverage, and documentation proof for accredited certification bodies.
Stage 1 Audit Binder (PDF)
Audit Reports Registry & Management Review Records (Audit > Audit reports)
Centralized access to download previously compiled audit packages, historical regulatory matrices, and signed ISO Clause 9.3 Management Review meeting minutes with SHA-256 hashes.
SHA-256 Verified (PDF)
Approved Policy Documents Export (Audit > Policy Documents Export)
Downloadable, versioned organizational operational policy documents across all five GRC pillars, complete with operative requirements, control mappings, and sign-offs.
5 GRC Pillars (PDF)

Infrastructure Location, Jurisdiction & Governmental Access Safeguards

TeamGRC hosts customer data exclusively in certified German data centers. This section sets out the verified hosting configuration, legal jurisdiction, foreign legal exposure analysis, and comprehensive safeguards against unlawful third-country governmental access to non-personal and personal data.

Confirmed Infrastructure Hosting Location

Exclusive European Hosting Region
All customer data, production databases, file storage buckets, compute runtimes, and internal support ticketing records are hosted exclusively within Amazon Web Services (AWS) Europe, Frankfurt, Germany. No other hosting region or secondary geographic data center is currently utilized for customer data.

The infrastructure scope encompasses:

  • Primary Hosting: High-availability AWS data centers located in Frankfurt am Main, Hesse, Germany, featuring biometric perimeter security, 24/7 armed surveillance, redundant power, and third-party certifications including ISO/IEC 27001, ISO 27017, ISO 27018, and SOC 2 Type II.
  • Data Redundancy & Backups: Database tables and storage buckets are synchronously replicated across three distinct Availability Zones within Frankfurt region. Automated weekly backups are maintained on a strict 90-day encrypted rotation cycle (MSA Section 19.2). No cross-region disaster recovery replication outside Germany is configured.
  • System Logging: Centralized AWS CloudTrail and Amazon CloudWatch log groups reside strictly in Frankfurt region, monitoring application activity with automated 24/7 alerting.
  • Support & Ticketing Access: All customer support tickets and uploaded case attachments are stored directly within isolated DB and objects storage partitions in Frankfurt. TeamGRC does not utilize third-party external ticketing vendors. Support triage is conducted strictly in-house by authorized personnel bound by written non-disclosure agreements.

Legal Jurisdiction & Foreign Law Exposure Analysis

Understanding infrastructure sovereignty requires distinguishing between physical data center locations, contractual governing law, and parent-company corporate structures:

TeamGRC Contractual Jurisdiction

TeamGRC Inc. operates European headquarters in Amstelveen, The Netherlands. Under MSA Section 20.1, the customer agreement is governed by the laws of The Netherlands, with exclusive jurisdiction resting in the District Court of Amsterdam (Rechtbank Amsterdam).

Cloud Infrastructure Provider

Cloud computing services are contracted through Amazon Web Services EMEA SARL (headquartered in Luxembourg), operating facilities through Amazon Data Services Germany GmbH in Frankfurt, subject to German and European Union law.

Important Legal Disclosure: EU Hosting Alone Does Not Immunize Against Foreign Subpoenas
While customer data is physically stored in Frankfurt, Germany, the underlying cloud provider is a subsidiary of Amazon.com, Inc., a United States multinational corporation. Under extraterritorial statutes such as the US CLOUD Act (18 U.S.C. § 2713) and FISA Section 702, US law enforcement and national security agencies may assert legal authority to compel US parent corporations to produce data stored by their foreign subsidiaries, irrespective of physical storage location. TeamGRC does not make false or misleading claims that European physical hosting alone prevents extraterritorial access requests.

Verified Technical Security Measures

To protect customer data and reduce the risk of interception, unauthorized access, disclosure, or alteration, TeamGRC applies the following technical security controls:

AES-256 Encryption at Rest

All customer records in DB tables, persistent objects storage, and automated snapshots are encrypted at rest using AES-256 via AWS Key Management Service (AWS KMS).

TLS 1.2 Encryption in Transit

All data moving across public networks is encrypted using TLS 1.2 (or higher) with modern cipher suites and Perfect Forward Secrecy (PFS), preventing eavesdropping or retro-decryption.

Tenant Logical Partitioning

Strict database partition key segregation (CompanyID / tenant) isolates customer data across DB and objects storage partitions. No shared, cross-tenant database rows or open buckets exist.

Access Control & Least Privilege

Internal access enforces strict role-based access control (RBAC) and mandatory multi-factor authentication (MFA). Across AWS cloud resources, granular, restrictive policies isolate each compute component on a strict least-privilege basis.

Cryptographic Integrity Hashing

Generated audit binders and compliance packages have SHA-256 integrity hashes computed upon creation, ensuring evidence immutability and instant detection of tampering.

Centralized Audit Logging

Centralized AWS CloudTrail and Amazon CloudWatch log groups record all administrative access, API calls, and system modifications, with automated anomaly alerting enabled 24/7.

Organisational & Contractual Safeguards Against Governmental Access

In accordance with the standards established by Article 28 of the EU Data Act for non-personal data held in the European Union, TeamGRC has contractually committed to and operationally established the following legal evaluation procedures:

Mandatory Legal Review of External Orders
Any request, subpoena, or warrant from a law enforcement or governmental authority seeking access to customer data is promptly referred to TeamGRC management via support@teamgrc.ai, with independent legal advice obtained where necessary. Before disclosing any data, TeamGRC assesses the request’s authenticity, legal basis, scope, and enforceability under applicable European Union and Dutch law. Any disclosure is limited to what is legally required.
Conflict of Laws Assessment & Legal Challenges
Where a request from a third-country authority conflicts with European Union law, fundamental human rights, or national Member State statutory secrecy obligations, TeamGRC commits to exhausting all reasonable and legally available avenues to challenge, quash, or modify the order before competent judicial authorities.
Customer Notification (MSA Section 12.4)
Pursuant to Section 12.4 of the Master Services Agreement, unless explicitly prohibited by a lawful statutory gag order or criminal law non-disclosure instruction, TeamGRC provides prompt advance written notice to the affected customer prior to disclosing any confidential information. This notice empowers the customer to seek a protective order, injunctive relief, or diplomatic intervention.
Strict Data Minimization
If disclosure is ultimately compelled by an unappealable judicial order, TeamGRC discloses only the minimum necessary data strictly required by law, actively opposing overbroad or blanket search warrants.

Subprocessor Contractual Safeguards (AWS Commitments)

TeamGRC maintains a direct contractual relationship with Amazon Web Services under the AWS Customer Agreement and the AWS EU Data Protection Addendum. Key subprocessor commitments established by AWS include:

  • Challenging Unlawful Requests: AWS formally commits to challenging any government request for data that is unlawful, overbroad, or in conflict with EU law.
  • Notice to Customers: AWS policy requires notifying the service provider before disclosing content data, unless prohibited by a court order.
  • Zero Direct Backdoors: AWS does not provide any government with direct, unfettered access or "backdoor" access to customer content stored in AWS data centers.

For further details on AWS infrastructure commitments, consult the official documentation:

AWS Government Requests Policy AWS EU Data Protection Center AWS Whitepaper: Government Requests

Relationship to Personal Data & Data Processing Addendum

While Article 28 of the EU Data Act governs international access to non-personal data, the processing of personal data (such as user account credentials, email addresses, and auditor names) is independently and strictly governed by TeamGRC’s Data Processing Addendum (DPA) (Exhibit D of the Master Services Agreement) pursuant to Article 28 of the EU General Data Protection Regulation (Regulation (EU) 2016/679, GDPR). Where applicable, transfers are reinforced by European Commission Standard Contractual Clauses (SCCs Module 2: Controller-to-Processor).

No Absolute Guarantees
In accordance with legal and technical honesty, TeamGRC does not state or imply absolute guarantees such as "foreign governments can never access your data." What TeamGRC provides and contractually guarantees is a robust, verifiable defense-in-depth framework comprising client-managed encryption, strict access controls, proactive legal challenges against unlawful requests, and prompt customer notification where legally permitted.

Transparency & Portability Enquiries

For all enquiries, including technical support, audit report generation, data exports, provider switching, hosting transparency, privacy, and legal matters, contact TeamGRC Support.

TeamGRC Support

Your central contact for all support requests and enquiries.

support@teamgrc.ai