Cloud adoption made a lot of things easier: faster rollout, less infrastructure to manage, and a cleaner path to scale. But it also introduced a subtle trap — one that shows up in audits, incident postmortems, and board discussions:

You can outsource operations, but you can’t outsource accountability.

That’s the heart of the shared responsibility model that every SaaS provider champions. SaaS providers secure and operate the service, but you remain responsible for your data, identities, configurations, and the business outcomes tied to them.

And that’s exactly why “having a backup” isn’t the finish line. Even if you back up your SaaS data, do you control where it’s stored, and are you confident about which laws apply to it? That’s where data sovereignty comes in.

Data sovereignty: If you own the risk, you need control

Data sovereignty, in a sense, is the shared responsibility model applied to jurisdiction and control. A provider may offer visibility or control of where and how data can be hosted, but the customer is accountable for understanding whether those offerings meet their sovereignty requirements, and then choosing architectures (including backup) that meet these demands.

In the simplest of terms, shared responsibility answers the “who,” and data sovereignty answers the “where.” Of course, that’s painting with a broad brush, so let’s go a bit into these.

The “who” (shared responsibility):

• Your SaaS provider is responsible for securing its service and maintaining availability of the data they hold for you.
• You’re responsible for your data, enabling access to the SaaS service, managing identity and configurations, and recoverability.

The “where” (data sovereignty):

• Where is your SaaS data stored and replicated?
• Where is your backup stored?
• Who ultimately controls the infrastructure that holds your data?
• Do the answers to these questions introduce new areas of risk?
• What jurisdictions can compel access — and how does that conflict with your local obligations?

This is the gap sovereignty helps close: You can be accountable for compliance and resilience outcomes (driven by your jurisdiction, customers, and risk appetite) without fully controlling the conditions required to meet them.

And importantly, the “where” doesn’t just mean the physical location of data. It includes the broader governance layer: legal jurisdiction, access pathways, dependency chains, and the practical ability to recover data on your terms.

What is data sovereignty?

At its simplest, sovereignty means autonomy: freedom from external control — meaning you are in control. What does that mean for data?

Digital sovereignty applies this concept to include an organization’s ability to maintain control over its digital infrastructure, such as data, operations, and technology, so it can decide where to store data and run workloads for reasons like performance, resilience, or regulatory alignment.

Data sovereignty is the data-specific part of digital sovereignty. It refers to which laws and regulations govern the storage and use of data — including how it can be used, who can access it, what obligations apply to it, and who decides these things.

This is where a common misconception creeps in: organizations often treat sovereignty as a “storage location” issue. Location matters, but data sovereignty is ultimately about control, jurisdiction, and enforceable obligations.

That’s why it helps to separate three related terms:

In modern environments, these lines blur quickly. Data can be collected in one country, processed in another, stored in a third, and backed up in a fourth, creating overlapping and sometimes conflicting obligations.

Why sovereignty gets complicated in SaaS

SaaS simplifies operations, but it can complicate sovereignty.

Here’s the core challenge: IT stacks are built on layered dependencies. Your business might run on SaaS apps that run on hyperscalers — and your backup might also run on those same hyperscalers. That creates four sovereignty problems at once:

1) You can’t always choose where data lives

Some SaaS platforms give customers meaningful options for data residency and regional hosting. Many don’t. In those cases, you get the provider’s default region(s), replication model, and sub-processor footprint — and you’re still accountable for the outcome. If you can’t select, constrain, or verify location, sovereignty becomes a constraint you inherit instead of a requirement you design for.

2) Compliance pressure is rising — and “we don’t control it” isn’t a defense

Regulators increasingly expect organizations to understand (and manage) where data is stored, who can access it, and what happens during disruption.

In Europe, this connects directly to resilience expectations in regulations like DORA and NIS2, which raise the bar on operational resilience, ICT (information and communication technology) risk management, and recovery readiness.

Around the world, people are beginning to have a strong preference to keep their data in the same country they’re in. Regulators are pushing for more transparency and accountability around cyber risk management and incidents, e.g., the SEC’s cybersecurity disclosure rules (for public companies) and privacy laws such as California’s CCPA statute (for consumer data handling and security expectations).

The point isn’t that every law explicitly says “data sovereignty.” The point is that obligations increasingly converge on the same reality: If your operations depend on data, you need to prove you can protect it, govern it, and recover it — even under stress.

3) Sovereignty is also a resilience issue

Sovereignty discussions often start with compliance, but they end up in resilience.

Why? Because geopolitical uncertainty, supply-chain fragility, and disruption scenarios can turn “the cloud” into a single point of failure, especially when multiple critical services share the same underlying infrastructure.

That matters for recovery. Many leaders assume: “No problem — we have backups.” But sovereignty changes what “backup” really means.

If your SaaS provider and your backup provider rely on the same hyperscaler infrastructure, you may have redundancy, but you don’t have independence. In certain scenarios, that can mean no separation of production and backup environments (no air gap), and therefore a weaker recovery posture. Read more about air gapping backups.

4) Control and lock-in are part of the sovereignty equation

Sovereignty isn’t only about where data is stored. It’s also about whether or not:

• You can prove where data is and who can access it
• Your backup environment is actually separate from external dependencies
• Third parties and sub-processors introduce indirect access paths

That’s why sovereignty becomes strategic: it forces organizations to look at cloud architecture, vendor reliance, cross-border replication, and operational control — not just checkbox compliance.

The crossroads of shared responsibility and data sovereignty

Responsibility without sovereignty puts you in a bad spot: you own the risk, but you don’t control the conditions that determine the outcome.

If you’re accountable for protecting and recovering SaaS data, you also need to be accountable for the sovereignty conditions that shape that protection and recovery, including:

1.     Compliance alignment

Sovereignty affects whether you can meet obligations tied to jurisdiction, access, and cross-border handling — especially when legal regimes conflict. For example, the GDPR explicitly addresses when a third-country authority can compel disclosure (see GDPR Article 48).

At the same time, the U.S. CLOUD Act can compel U.S.-based service providers to disclose data within their control, regardless of where that data is stored — creating a governance and risk question many organizations now have to evaluate.

2.     Resilience and recovery

True resilience depends on being able to recover data even when your source SaaS provider is down, compromised, or inaccessible. That’s hard to guarantee if your “backup” is effectively another service running inside the same dependency chain.

A sovereignty-aware resilience posture typically requires:

• immutable protection (to reduce tampering and corruption risk)
• independent infrastructure (so recovery doesn’t depend on the same upstream provider or hyperscaler)
• geographic choice (to allow you to choose locations that align with your residency and operational requirements)

3.     Control and strategic flexibility

Sovereignty is also about the ability to make future choices:

• moving workloads
• changing providers
• meeting new rules
• adapting to geopolitical shifts
• maintaining auditability and transparency

If your backup strategy can’t support those outcomes, then your shared responsibility obligations get harder over time.

What “sovereign backup” looks like in practice

Most organizations don’t need ideology; they need criteria. A sovereignty-aligned approach to SaaS data protection typically includes:

• Immutable, independent backup
  Backups should be segregated from production environments and designed for recovery even if the primary platform is unavailable or compromised.
• Vendor neutrality and platform separation
  If your backup runs on the same underlying hyperscaler as your SaaS application, you may have backups, but you may not have the level of independence that sovereignty and resilience goals demand.
• Data residency options and transparency
  You need clarity on where data is stored, how it moves, and how you prove it, especially when obligations vary across regions and industries.
• An exit plan that works under pressure
  Sovereignty is also the ability to leave. That means usable export formats, retrieval SLAs, and recovery planning that isn’t theoretical.

Closing thought: The next “layer” of shared responsibility

The shared responsibility model explains why customers must protect their own SaaS data. Data sovereignty explains how they must do it to ensure control, compliance, and resilience.

If you’re building a SaaS resilience strategy, don’t stop at “do we have backup?”
Ask the next question: Is our backup sovereign by design?

If you want the deeper framework — definitions, real-world examples, and a practical action plan — download the data sovereignty report.