We would like to ask about Azure CDN-hosted web application's data protection concerns. We heard that German's personal identifiable information (PII) regulation is one of the highest levels, and therefore we deployed the service on German West Central region. However, we understood CDN is essentially global and the data flow may not be closed inside the user's country. It is an obvious problem if the user input data is transferred to USA. But we are not sure if there are any guaranteed restrictions of data flow on the CDN provider. Is there a way to assert that the data is protected for German users?. For the CDN resource's region setting, since German West Central was not in the selection list, we next option selected was West EU. Our understanding is that the region is only used for the metadata. Can you please clarify the best approach under the PII regulation framework?

Hello Claudio Roselli , Welcome to the Microsoft Q&A and thank you for posting your questions here. I understand regarding your explanation that you have concerns about Data Flow Restrictions, Region Setting for CDN and Compliance with German PII Regulations. Below addresses your concerns and questions, provides a recommended approach and references for more information: Azure CDN, being a globally distributed service, does not ensure that all user data will remain within a specific region. This is because CDN nodes are strategically placed worldwide to optimize performance. However, you can leverage Azure Front Door or Azure Traffic Manager to route traffic based on geographic regions, which helps in controlling data flow and ensuring compliance with local regulations. The region setting for CDN resources primarily influences metadata and management operations, rather than guaranteeing that user data will stay within that region. For more stringent data residency requirements, consider using Azure Front Door with regional restrictions to better control where your data is processed and stored. To ensure compliance with German PII regulations, configure your Azure services to meet the C5:2020 standard and other relevant data protection laws. This includes using encryption for data at rest and in transit, implementing strict access controls, and conducting regular audits to maintain ongoing compliance. References: Traffic routing methods to origin - Azure Front Door Azure Front Door sensitive data protection Azure Front Door and CDN Documentation I hope this is helpful! Do not hesitate to let me know if you have any other questions. Please don't forget to close up the thread here by upvoting and accept it as an answer if it is helpful.

Azure CDN-hosted and PII Regulation

Accepted answer

Sina Salam 16,446 Reputation points

2025-01-16T13:10:48.63+00:00
Hello Claudio Roselli,

Welcome to the Microsoft Q&A and thank you for posting your questions here.

I understand regarding your explanation that you have concerns about Data Flow Restrictions, Region Setting for CDN and Compliance with German PII Regulations.

Below addresses your concerns and questions, provides a recommended approach and references for more information:

Azure CDN, being a globally distributed service, does not ensure that all user data will remain within a specific region. This is because CDN nodes are strategically placed worldwide to optimize performance. However, you can leverage Azure Front Door or Azure Traffic Manager to route traffic based on geographic regions, which helps in controlling data flow and ensuring compliance with local regulations.

The region setting for CDN resources primarily influences metadata and management operations, rather than guaranteeing that user data will stay within that region. For more stringent data residency requirements, consider using Azure Front Door with regional restrictions to better control where your data is processed and stored.

To ensure compliance with German PII regulations, configure your Azure services to meet the C5:2020 standard and other relevant data protection laws. This includes using encryption for data at rest and in transit, implementing strict access controls, and conducting regular audits to maintain ongoing compliance.

References:

Traffic routing methods to origin - Azure Front Door

Azure Front Door sensitive data protection

Azure Front Door and CDN Documentation

I hope this is helpful! Do not hesitate to let me know if you have any other questions.

Please don't forget to close up the thread here by upvoting and accept it as an answer if it is helpful.
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1 person found this answer helpful.
Claudio Roselli 30 Reputation points

2025-01-18T12:48:30.9033333+00:00

Hi @Sina Salam

My team and I are reviewing the answers. I’ll come back to you next week.

many thanks

Claudio Roselli 30 Reputation points

2025-01-22T10:57:04.9266667+00:00

Hi @Sina Salam

My team raised the following question:

How can we achieve the geographic regional traffic control without Private Link feature of the Premium tier?

Clarify a bit more detailed architecture of the suggested implementation which uses Front Door and/or Traffic Manager.

Regards,

Claudio R

Sina Salam 16,446 Reputation points

2025-01-22T14:35:04.23+00:00

Dear Claudio Roselli,

Thank you for your feedback and for letting me know your next questions:

Achieving Geographic Regional Traffic Control Without Private Link,

To achieve geographic regional traffic control without relying on the Premium-tier Private Link feature:

Leverage Azure Front Door Standard (or Premium without Private Link) with Geofilter Rules: Use Front Door's path-based routing and geographic filtering to control traffic based on the client's geographic location.

Configure the backend pools with region-specific endpoints, ensuring traffic from a specific region is routed only to the corresponding backend.

Alternatively, you can use Azure Traffic Manager with Geofencing by:

Configure Azure Traffic Manager to route traffic to region-specific Azure resources using geographic routing.

Deploy region-specific app services or VMs to ensure data remains within desired jurisdictions.

Thirdly, Backend Region Restriction:

Enforce region-specific data processing by deploying regional instances of your application or storage (e.g., German Azure regions).

Implement strict access control via NSG (Network Security Groups) or App Gateway WAF rules to restrict cross-region traffic.

Finally, DNS and Compliance

Ensure DNS queries resolve to region-specific endpoints for user requests.

Use Azure Policy to enforce compliance rules, such as ensuring data stays within specific regions and meets GDPR or German compliance standards.

About detailed Architecture

A more detailed architecture could look like this:

Azure Front Door (Standard):

Set up Front Door to route traffic to region-specific backend pools based on the client’s geographic location using path-based and geofilter routing.

Each backend pool contains only endpoints in a specific region, e.g., Germany or EU regions.

Configure HTTPS to secure traffic and encrypt data in transit.

Azure Traffic Manager (Optional):

If multi-regional Front Door deployment isn't feasible, use Traffic Manager for geo-routing to regional Front Door instances or App Gateways.

Ensure the selected endpoint aligns with the client’s geographic origin.

Data Residency Enforcement:

Deploy separate instances of your application and data resources in each region.

Use Azure Key Vault and Managed Identity for secure access and encryption.

Monitor traffic flow using Azure Monitor and Log Analytics to audit data access and ensure compliance.

Application Layer Security:

Use Application Gateway (WAF) in each region to add an additional layer of security, ensuring that traffic adheres to compliance standards.

NOTE:

Ensure all storage and processing meet the German PII regulations and GDPR.

Use Standard-tier Front Door and Traffic Manager instead of Premium-tier Front Door with Private Link to save costs.

Design the architecture to scale regionally, accommodating high traffic without violating compliance.

References:

https://learn.microsoft.com/en-us/azure/frontdoor/front-door-routing-methods#geographic-routing

https://learn.microsoft.com/en-us/azure/traffic-manager/traffic-manager-routing-methods#geographic-routing

https://learn.microsoft.com/en-us/azure/governance/policy/overview

Goodluck.

Please, do not forget to close the thread by upvoting and accept as an answer. Thank you.
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