PagerDuty GDPR compliance: Data processing, DPA terms, and EU data residency

PagerDuty's GDPR compliance involves operating as a data processor under Article 28, with its services primarily hosted in AWS Frankfurt to meet EU data residency requirements. Its compliance strategy includes binding Data Processing Agreements, sub-processor disclosures, and encryption of personal data. However, challenges persist, such as limited audit log access and potential cross-border data flow issues, which require organizations to verify data residency pinning and sub-processor security independently. The platform provides a sub-processor list and RSS feed for updates, with a 30-day objection window for changes. Incident.io offers an alternative with stricter regional data isolation, automated audit logs, and enhanced compliance controls, addressing some of PagerDuty's limitations and providing tools for seamless migration, including support for private incident management and SCIM provisioning for efficient user access control. Compliance teams must navigate these complexities to ensure adherence to GDPR obligations while managing vendor risks and maintaining robust incident management capabilities.

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