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        <title><![CDATA[ The Cloudflare Blog ]]></title>
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            <title>The Cloudflare Blog</title>
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        <lastBuildDate>Fri, 03 Apr 2026 07:05:42 GMT</lastBuildDate>
        <item>
            <title><![CDATA[Expanding Regional Services configuration flexibility for customers]]></title>
            <link>https://blog.cloudflare.com/expanding-regional-services-configuration-flexibility-for-customers/</link>
            <pubDate>Wed, 22 May 2024 13:00:54 GMT</pubDate>
            <description><![CDATA[ Today we're happy to announce expanded capabilities that will allow you to configure Regional Services for an increased set of defined regions to help you meet your specific requirements for being able to control where your traffic is handled ]]></description>
            <content:encoded><![CDATA[ <p></p>
            <figure>
            
            <img src="https://cf-assets.www.cloudflare.com/zkvhlag99gkb/3L6Lyw3KVz8EXqwjkYjzcm/225c646ec28e34d095e403a99495466f/image1-9.png" />
            
            </figure><p>When we <a href="/introducing-regional-services/">launched</a> Regional Services in June 2020, the concept of <a href="https://www.cloudflare.com/learning/privacy/what-is-data-localization/">data locality and data sovereignty</a> were very much rooted in European regulations. Fast-forward to today, and the pressure to localize data persists: Several countries have laws requiring data localization in some form, public-sector contracting requirements in many countries require their vendors to restrict the location of data processing, and some customers are reacting to geopolitical developments by seeking to exclude data processing from certain jurisdictions.</p><p>That’s why today we're happy to announce expanded capabilities that will allow you to configure Regional Services for an increased set of defined regions to help you meet your specific requirements for being able to control where your traffic is handled. These new regions are available for early access starting in late May 2024, and we plan to have them generally available in June 2024.</p><p>It has always been our goal to provide you with the toolbox of solutions you need to not only address your security and performance concerns, but also to help you meet your legal obligations. And when it comes to data localization, we know that some of you need to have data stay in a particular jurisdiction, while others need data to avoid certain jurisdictions. In response to these needs, we’ve expanded our Regional Services toolbox of offerings to help you more precisely determine where traffic is inspected. Some of these new Regional Services offerings allow you to restrict inspection of data to only those data centers within jurisdictional boundaries, such as Brazil, Saudi Arabia, and Switzerland. Others will allow you to permit inspection of data everywhere except certain jurisdictions, such as our new Exclusive of Hong Kong and Macau offering and our Exclusive of Russia and Belarus offering. And we’ve also listened to customers who are eager to demonstrate their commitment to sustainability by offering our Cloudflare Green Energy region, which limits inspection of data to those data centers that are committed to powering their operations with renewable energy.</p><p>The new regions include some of our most requested areas and specifications:</p><p>Austria, Brazil, Cloudflare Green Energy, Exclusive of Hong Kong and Macau, Exclusive of Russia and Belarus, France, Hong Kong, Italy, NATO, the Netherlands, Russia, Saudi Arabia, South Africa, Spain, Switzerland, and Taiwan.</p><p>A full list of our Regional Services offerings can be found <a href="https://developers.cloudflare.com/data-localization/region-support/">here.</a></p>
    <div>
      <h3>A note on our framework for data localization going forward</h3>
      <a href="#a-note-on-our-framework-for-data-localization-going-forward">
        
      </a>
    </div>
    <p>Over the course of the next year, you are going to see new and exciting ways to use Cloudflare products to help keep your data local. But doesn’t this contradict the whole premise of Cloudflare? Aren't we a global anycast network that believes in Region Earth?</p><p>We don’t believe these have to be an either/or conversation. While we continue to believe that data localization should not be a proxy for privacy and that restrictions on cross border data transfers are <a href="https://itif.org/publications/2021/07/19/how-barriers-cross-border-data-flows-are-spreading-globally-what-they-cost/">harmful to global commerce</a>, we remain committed to supporting those of you who need data localization solutions to address your legal obligations and risk tolerance.</p><p>Unfortunately, many different cloud providers have decided that the best way to meet the compliance needs of their customers is to create fixed infrastructure deployments called sovereign clouds. The trouble with these infrastructure deployments is that you have to commit all of your traffic to be regionalized, regardless of whether all of that traffic actually needs to be confined to a specific data center in a specific region.</p><p>As we continue to ramp up development of our Data Localization Suite, I want to lay out the questions that are guiding our thought process:</p><p>What if there was a better way forward that lets you regionalize exactly what you need to, without having to localize everything, giving you the best of compliance and performance? What would customers build if they could localize the APIs that handled private customer information, while also serving their static assets globally? How could we increase the compliance and privacy of our customers' <a href="https://www.cloudflare.com/learning/security/glossary/what-is-zero-trust/">Zero Trust</a> deployments if we could let them choose where their security processing occurred? What if they could define custom regions, and apply those regions to specific hostnames and Cloudflare products while also being able to use <a href="https://developers.cloudflare.com/byoip/">BYOIP</a> or <a href="https://developers.cloudflare.com/spectrum/about/static-ip/">Static IP</a>?</p><p>We call this approach software defined regionalization (SDR)  and we believe that it is the future of data localization. Using our global network as the foundation, SDR allows our customers to make exceptionally granular choices about what traffic to regionalize and where to regionalize it. This empowers you to build applications that are fast, reliable, and compliant without having to deploy new physical infrastructure or have multiple cloud deployments for the same application.</p><p>Taking it a step further, SDR allows you to shape Cloudflare to meet both current and future needs. It gives you the flexibility to quickly respond to new challenges in a rapidly changing world. By making localization choices in software, you are not bound by the physical constraints of your existing network geography or the locations of your cloud deployments.</p><p>We believe that software defined regionalization is the future of data localization, and we are excited to be on the forefront of its development.</p>
    <div>
      <h3>How Regional Services ensures your data is processed in the correct region</h3>
      <a href="#how-regional-services-ensures-your-data-is-processed-in-the-correct-region">
        
      </a>
    </div>
    <p>Complying with data localization requirements isn't possible without strong encryption; otherwise, anyone could snoop on your customers' data, regardless of where it's stored. Strong encryption is the foundation of Regional Services.</p><p>Data is often described as being "in transit" and "at rest". It's critically important that both are encrypted. Data "in transit" refers to just that – data while it's moving about on the wire, whether a local network or the public Internet. "At rest" generally means stored on a disk somewhere, whether a spinning hard disk or a modern solid state disk.</p><p>In transit, Cloudflare can enforce that all traffic uses modern <a href="https://www.cloudflare.com/learning/ssl/transport-layer-security-tls/">TLS</a> and gets the highest level of encryption possible. We can also enforce that all traffic back to customers' origin servers is always encrypted. Communication between all of our edge and core data centers is always encrypted.</p><p>Cloudflare encrypts all the data we handle at rest, with disk-level encryption. From cached files on our edge network, to configuration state in databases in our core data centers – every byte is encrypted at rest.</p><p>How then can we also regionalize the traffic if it’s encrypted? All of Cloudflare's data centers advertise the same IP addresses through <a href="https://www.cloudflare.com/learning/security/glossary/what-is-bgp/">Border Gateway Protocol (BGP)</a>. Whichever data center is closest to an end user from a network point of view is the one that they will hit.</p><p>This is great for two reasons. The first is that the closer the data center is to an eyeball, the faster the reply. The second great benefit is that this comes in very handy when dealing with large <a href="https://www.cloudflare.com/learning/ddos/what-is-a-ddos-attack/">DDoS attacks</a>. Volumetric DDoS attacks throw a lot of bogus traffic at a particular application, which overwhelms network capacity. Cloudflare's anycast network is great at taking on these attacks because they get distributed across the entire network, and mitigated close to where they originate.</p><p>Anycast doesn't respect regional borders – it doesn't even know about them. Which is why, out of the box, Cloudflare can't guarantee that traffic from inside a country will also be serviced there. Typically, requests hit a data center inside the originating country, but it’s possible that the user’s Internet Service Provider will send traffic to a network that might route it to a different country.</p><p>Regional Services solves that: when turned on, each data center becomes aware of which regional services-defined boundary it is operating in. If a customer’s end user hits a Cloudflare data center that doesn't match the region that the customer has selected, we simply forward the raw TCP stream in encrypted form. Once it reaches a data center inside the right region, we decrypt and apply all of our Layer 7 products. This covers products such as <a href="https://www.cloudflare.com/application-services/products/cdn/">CDN</a>, <a href="https://www.cloudflare.com/application-services/products/waf/">WAF</a>, <a href="https://www.cloudflare.com/application-services/products/bot-management/">Bot Management</a>, and <a href="https://www.cloudflare.com/developer-platform/workers/">Workers</a>.</p><p>Let's take an example. A customer’s end user is in Kerala, India, and BGP has determined that the optimal data center for that end user’s request is in Colombo, Sri Lanka. In this example, a customer may have selected India as the sole region within which traffic should be serviced. The Colombo data center sees that this traffic is meant for the India region. It does not decrypt, but instead forwards it to a data center inside India. There, we decrypt and products such as WAF and Workers are applied as if the traffic had hit the data center directly. Responses from the in-region data center retrace the same path back to the client.</p>
            <figure>
            
            <img src="https://cf-assets.www.cloudflare.com/zkvhlag99gkb/4sR2CvzCEuQl5zxW7CVGzx/9aecf2e4b9c80655df7f5eda3e9a1084/image2-8.png" />
            
            </figure><p>Our expanded Regional Services capabilities are available for early access in late May 2024, and we plan to have them generally available in June 2024. We are very excited about our ability to develop our Data Localization Suite to help you meet your data localization needs.</p><p>To get access to these expanded capabilities, or if you’re interested in using the <a href="https://www.cloudflare.com/data-localization/">Data Localization Suite</a>, contact your account team.</p> ]]></content:encoded>
            <category><![CDATA[Data Localization]]></category>
            <guid isPermaLink="false">4bq9x0Ufo3Aer4qQM4B4I1</guid>
            <dc:creator>Wesley Evans</dc:creator>
        </item>
        <item>
            <title><![CDATA[One-click ISO 27001 certified deployment of Regional Services in the EU]]></title>
            <link>https://blog.cloudflare.com/one-click-iso-27001-deployment/</link>
            <pubDate>Sat, 18 Mar 2023 15:00:00 GMT</pubDate>
            <description><![CDATA[ Cloudflare announces one-click ISO certified region, a super easy way for customers to limit where traffic is serviced to ISO 27001 certified data centers inside the European Union ]]></description>
            <content:encoded><![CDATA[ <p></p>
            <figure>
            
            <img src="https://cf-assets.www.cloudflare.com/zkvhlag99gkb/6aVTJdGy7JkjPxS0Z827zC/93d84cd6fc8321a8ecdb60b48f476041/Regional-Services-one-click-limit-traffic-to-ISO-27001-certified-colos-only.png" />
            
            </figure><p>Today, we’re very happy to announce the general availability of a new region for Regional Services that allows you to limit your traffic to only <a href="https://www.iso.org/isoiec-27001-information-security.html">ISO 27001</a> certified data centers inside the EU. This helps customers that have very strict requirements surrounding which data centers are allowed to decrypt and service traffic. Enabling this feature is a one-click operation right on the Cloudflare dashboard.</p>
    <div>
      <h3>Regional Services - a recap</h3>
      <a href="#regional-services-a-recap">
        
      </a>
    </div>
    <p>In 2020, we saw an increase in prospects asking about data localization. Specifically, increased regulatory pressure limited them from using vendors that operated at global scale. We launched <a href="/introducing-regional-services/">Regional Services</a>, a new way for customers to use the Cloudflare network. With Regional Services, we put customers back in control over which data centers are used to service traffic. Regional Services operates by limiting exactly which data centers are used to decrypt and service HTTPS traffic. For example, a customer may want to use only data centers inside the European Union to service traffic. Regional Services operates by leveraging our global network for DDoS protection but only decrypting traffic and applying Layer 7 products inside data centers that are located inside the European Union.</p><p>We later followed up with the <a href="https://www.cloudflare.com/data-localization/">Data Localization Suite</a> and additional regions: <a href="/regional-services-comes-to-apac/">India, Japan, and Australia</a>.</p><p>With Regional Services, customers get the best of both worlds: we empower them to use our global network for volumetric DDoS protection whilst limiting where traffic is serviced. We do that by accepting the raw TCP connection at the closest data center but forwarding it on to a data center in-region for decryption. That means that only machines of the customer’s choosing actually see the raw HTTP request, which could contain sensitive data such as a customer’s bank account or medical information.</p>
    <div>
      <h3>A new region and a new UI</h3>
      <a href="#a-new-region-and-a-new-ui">
        
      </a>
    </div>
    <p>Traditionally we’ve seen requests for data localization largely center around countries or geographic areas. Many types of regulations require companies to make promises about working only with vendors that are capable of restricting where their traffic is serviced geographically. Organizations can have many reasons for being limited in their choices, but they generally fall into two buckets: compliance and contractual commitments.</p><p>More recently, we are seeing that more and more companies are asking about security requirements. An often asked question about security in IT is: how do you ensure that something is safe? For instance, for a data center you might be wondering how physical access is managed. Or how often security policies are reviewed and updated. This is where certifications come in. A common certification in IT is the <a href="https://en.wikipedia.org/wiki/ISO/IEC_27001">ISO 27001 certification</a>:</p><p>Per the <a href="https://www.iso.org/isoiec-27001-information-security.html">ISO.org</a>:</p><blockquote><p><i>“ISO/IEC 27001 is the world’s best-known standard for information security management systems (ISMS) and their requirements. Additional best practice in data protection and cyber resilience are covered by more than a dozen standards in the ISO/IEC 27000 family. Together, they enable organizations of all sectors and sizes to manage the security of assets such as financial information, intellectual property, employee data and information entrusted by third parties.”</i></p></blockquote><p>In short, ISO 27001 is a certification that a data center can achieve that ensures that they maintain a set of security standards to keep the data center secure. With the new Regional Services region, HTTPS traffic will only be decrypted in data centers that hold the ISO 27001 certification. Products such as WAF, Bot Management and Workers will only be applied in those relevant data centers.</p><p>The other update we’re excited to announce is a brand new User Interface for configuring the Data Localization Suite. The previous UI was limited in that customers had to preconfigure a region for an entire zone: you couldn’t mix and match regions. The new UI allows you to do just that: each individual hostname can be configured for a different region, directly on the DNS tab:</p>
            <figure>
            
            <img src="https://cf-assets.www.cloudflare.com/zkvhlag99gkb/60Ech3V5DIBzcXCKC79TU3/2e16686487cbbad51c77a3f896d9be87/pasted-image-0--5--3.png" />
            
            </figure><p>Configuring a region for a particular hostname is now just a single click away. Changes take effect within seconds, making this the easiest way to configure data localization yet. For customers using the Metadata Boundary, we’ve also launched a self-serve UI that allows you to configure where logs flow:</p>
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            <img src="https://cf-assets.www.cloudflare.com/zkvhlag99gkb/62faVgbaj8GXkZtHrCX5xR/717d4b892a5f1f78c4b8c503a549c65c/image-13.png" />
            
            </figure><p>We’re excited about these new updates that give customers more flexibility in choosing which of Cloudflare’s data centers to use as well as making it easier than ever to configure them. The new region and existing regions are now a one-click configuration option right from the dashboard. As always, we love getting feedback, especially on what new regions you’d like to see us add in the future. In the meantime, if you’re interested in using the Data Localization Suite, please reach out to your account team.</p> ]]></content:encoded>
            <category><![CDATA[Security Week]]></category>
            <category><![CDATA[Data Localization]]></category>
            <category><![CDATA[Compliance]]></category>
            <category><![CDATA[Certification]]></category>
            <category><![CDATA[Regional Services]]></category>
            <category><![CDATA[Product News]]></category>
            <guid isPermaLink="false">4eu3YHNrghYyABVfdr9okM</guid>
            <dc:creator>Achiel van der Mandele</dc:creator>
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        <item>
            <title><![CDATA[Navigating the changing data localization landscape with Cloudflare’s Data Localization Suite]]></title>
            <link>https://blog.cloudflare.com/dls-2022/</link>
            <pubDate>Thu, 26 Jan 2023 14:00:00 GMT</pubDate>
            <description><![CDATA[ We continue to expand and improve our data localization suite to help support our customers who have to comply with data localization requirements ]]></description>
            <content:encoded><![CDATA[ <p></p>
            <figure>
            
            <img src="https://cf-assets.www.cloudflare.com/zkvhlag99gkb/4EYiLjXGqj15qzzu24PmZ3/bfc3ae0c89d06eede8899add141bf3fc/image1-51.png" />
            
            </figure><p>At Cloudflare, we believe that deploying effective <a href="https://www.cloudflare.com/learning/security/what-is-cyber-security/">cybersecurity</a> measures is the <a href="/investing-in-security-to-protect-data-privacy/">best way to protect</a> the privacy of personal information and can be more effective than making sure that information stays within a particular jurisdiction. Yet, we hear from customers in Europe, India, Australia, Japan, and many other regions that, as part of their privacy programs, they need solutions to localize data in order to meet their regulatory obligations.</p><p>So as we think about Data Privacy Day, which is coming up on January 28, we are in the interesting position of disagreeing with those who believe that data localization is a proxy for better data privacy, but of also wanting to support our customers who have to comply with certain regulations.</p><p>For this reason, we <a href="/introducing-the-cloudflare-data-localization-suite/">introduced our Data Localization Suite</a> (DLS) in 2020 to help customers navigate a data protection landscape that focuses more and more on data localization. With the DLS, customers can use Cloudflare’s powerful global network and security measures to protect their businesses, while keeping the data we process on their behalf local. Since its launch, we’ve had many customers adopt the Data Localization Suite. In this blog post we want to share updates about how we’re making the DLS more comprehensive and easier to use.</p>
    <div>
      <h3>The confusing state of data protection regulations</h3>
      <a href="#the-confusing-state-of-data-protection-regulations">
        
      </a>
    </div>
    <p>We frequently field questions from customers who hear about new local laws or interpretations of existing regulations that seem to limit what they can do with data. This is especially confusing for customers doing business on the global Internet because they have to navigate regulations that suggest customers based in one country can’t use products from companies based in another country, unless extensive measures are put in place.</p><p>We don’t think this is any way to regulate the Internet. As we’ll talk more about in our blog post tomorrow about cross-border data transfers, we’re encouraged to see new developments aimed at establishing a common set of data protections across jurisdictions to make these data transfers more seamless.</p><p>In the meantime, we have the Data Localization suite to help our customers navigate these challenges.</p>
    <div>
      <h3>A recap of how the Data Localization Suite works</h3>
      <a href="#a-recap-of-how-the-data-localization-suite-works">
        
      </a>
    </div>
    <p>We developed DLS to address three primary customer concerns:</p><ol><li><p>How do I ensure my encryption keys stay in my jurisdiction?</p></li><li><p>How can I ensure that application services like caching and <a href="https://www.cloudflare.com/learning/ddos/glossary/web-application-firewall-waf/">WAF</a> only run in my jurisdiction?</p></li><li><p>How can I ensure that logs and metadata are never transferred outside my jurisdiction?</p></li></ol><p>To address these concerns, our DLS has an encryption key component, a component that addresses where content in transit is terminated and inspected, and a component that keeps metadata within a customers’ jurisdiction:</p><p><b>1. Encryption Keys</b>Cloudflare has long offered <a href="https://www.cloudflare.com/ssl/keyless-ssl/">Keyless SSL</a> and <a href="/introducing-cloudflare-geo-key-manager/">Geo Key Manager</a>, which ensure that private SSL/TLS key material never leaves the EU. Customers using our Geo Key Manager can choose for encryption keys to be stored only in data centers in the region the customer specifies. Keyless SSL ensures that Cloudflare never has possession of the private key material at all; Geo Key Manager ensures that keys are protected with cryptographic access control, so they can only be used in specified regions.</p><p><b>2. </b><a href="/introducing-regional-services/"><b>Regional Services</b></a>:Regional Services ensures that Cloudflare will only be able to decrypt and inspect the content of HTTPS traffic inside a customer’s chosen region. When Regional Services is enabled, regardless of which data center traffic first hits on our global network, rather than decrypting it at the first data center, we forward the TCP stream in encrypted form. Once it reaches a data center inside the customer’s chosen region, we decrypt and apply our Layer 7 security measures to prevent malicious traffic from reaching our customers’ websites.</p><p><b>3. </b><a href="/introducing-the-customer-metadata-boundary/"><b>Customer Metadata Boundary</b></a>:With this option enabled, no end user traffic logs (which contain IP addresses) that Cloudflare processes on behalf of our customers will leave the region chosen by the customer. (Currently available only in the EU and US.)</p>
    <div>
      <h3>Expanding Data Localization Suite to new regions</h3>
      <a href="#expanding-data-localization-suite-to-new-regions">
        
      </a>
    </div>
    <p>Although we launched the Data Localization Suite with Europe and America in mind at first, we quickly realized a lot of our customers were interested in versions specific to the Asia-Pacific region as well. In September of last year, we added <a href="/regional-services-comes-to-apac/">support for Regional Services</a> in Japan, Australia, and India.</p><p>Then in December 2022 we announced that Geo Key Manager is now accessible in <a href="/configurable-and-scalable-geo-key-manager-closed-beta/">15 regions</a>. Customers can both allow- and deny-list the regions that they want us to support for fine-grained control over where their key material is stored.</p><p>See also our <a href="/inside-geo-key-manager-v2">technical deep dive</a> about how we built Geo Key Manager v2.</p>
    <div>
      <h3>Making data localization more accessible</h3>
      <a href="#making-data-localization-more-accessible">
        
      </a>
    </div>
    <p>Regional Services and the Customer Metadata Boundary offer important protections for our customers — but they’ve been too hard to use. Both have required manual steps taken by teams at Cloudflare, and have had confusing (or no) public APIs.</p><p>Today, we’re fixing that! We’re excited to announce two big improvements to usability:</p><ol><li><p>Regional Services customers now have a dedicated UI and <a href="https://developers.cloudflare.com/data-localization/regional-services/get-started/#configure-regional-services-via-api">API for enabling Regional Services</a>, accessible straight from the DNS tab. Different regions can now be set on a per-hostname basis</p></li><li><p>Customers who want to use the Metadata Boundary can use <a href="https://developers.cloudflare.com/data-localization/metadata-boundary/get-started/">our self-service API</a> to enable it.</p></li></ol><p>We’re excited about making it easier to use the Data Localization Suite and give customers more control over exactly how to localize which parts of their traffic.</p>
    <div>
      <h3>What’s next</h3>
      <a href="#whats-next">
        
      </a>
    </div>
    <p>The Data Localization Suite is accessible today for enterprise customers. Please chat with your account representative if you’re interested in using it, and you can <a href="https://developers.cloudflare.com/data-localization/">find more information here</a> about configuring it in our developer docs.</p><p>We have lots more planned for the Data Localization Suite this year. We plan to support many more regions for Regional Services and the Metadata Boundary. We also plan to have full data localization support for all of our Zero Trust products. Stay tuned to the blog for more!</p> ]]></content:encoded>
            <category><![CDATA[Data Privacy Day]]></category>
            <category><![CDATA[Data Localization]]></category>
            <category><![CDATA[Data Localization Suite]]></category>
            <category><![CDATA[Policy & Legal]]></category>
            <guid isPermaLink="false">6Rg92MVxprXul5pDi5Z5tk</guid>
            <dc:creator>Emily Hancock</dc:creator>
            <dc:creator>Jon Levine</dc:creator>
        </item>
        <item>
            <title><![CDATA[Data Privacy Day 2021 - Looking ahead at the always on, always secure, always private Internet]]></title>
            <link>https://blog.cloudflare.com/data-privacy-day-2021-looking-ahead-at-the-always-on-always-secure-always-private-internet/</link>
            <pubDate>Thu, 28 Jan 2021 09:00:00 GMT</pubDate>
            <description><![CDATA[ 2020 was a big year for data protection, so what does 2021 have in store? On Data Privacy Day, we talk about the role data localization and encryption technologies play in data protection. ]]></description>
            <content:encoded><![CDATA[ <p></p><p>Welcome to Data Privacy Day 2021! Last year at this time, I was writing about how <a href="/empowering-your-privacy/">Cloudflare builds privacy into everything we do</a>, with little idea about how dramatically the world was going to change. The tragedy of the COVID-19 pandemic has reshaped the way we go about our daily lives. Our dependence on the Internet grew exponentially in 2020 as we started working from home, attending school from home, and participating in online weddings, concerts, parties, and more. So as we begin this new year, it’s impossible to think about data privacy in 2021 without thinking about how an <a href="/internet-privacy/">always-on, always secure, always private Internet</a> is more important than ever.</p><p>The pandemic wasn’t the only thing to dramatically shape data privacy conversations last year. We saw a flurry of new activity on data protection legislation around the globe, and a trend toward data localization in a variety of jurisdictions.</p><p>I don’t think I’m taking any risks when I say that 2021 looks to be another busy year in the world of privacy and data protection. Let me tell you a bit about what that looks like for us at Cloudflare. We’ll be spending a lot of time in 2021 helping our customers find the solutions they need to meet data protection obligations; enhancing our technical, organizational, and contractual measures to protect the privacy of personal data no matter where in the world it is processed; and continuing to develop privacy-enhancing technologies that can help everyone on the Internet.</p>
    <div>
      <h3>Focus on International Data Transfers</h3>
      <a href="#focus-on-international-data-transfers">
        
      </a>
    </div>
    <p>One of the biggest stories in data protection in 2020 was the Court of Justice of the European Union’s decision in the “Schrems II” case (Case C-311/18, <i>Data Protection Commissioner v Facebook Ireland and Maximillian Schrems</i>) that invalidated the EU-U.S. Privacy Shield. The court’s interpretation of U.S. surveillance laws meant that data controllers transferring EU personal data to U.S. data processors now have an obligation to make sure additional safeguards are in place to provide the same level of data protection as the General Data Protection Regulation (“GDPR”).</p><p>The court decision was followed by draft guidance from the European Data Protection Board (EDPB) that created new expectations and challenges for transfers of EU personal data to processors outside the EU pursuant to the GDPR. In addition, the EU Commission issued new draft standard contractual clauses that further emphasized the need for data transfer impact assessments and due diligence to be completed prior to transferring EU personal data to processors outside the EU. Meanwhile, even before the EDPB and EU Commission weighed in, France’s data protection authority, the CNIL, challenged the use of a U.S. cloud service provider for the processing of certain health data.</p><p>This year, the EDPB is poised to issue its final guidance on international data transfers, the EU Commission is set to release a final version of new standard contractual clauses, and the new Biden administration in the United States has already appointed a deputy assistant secretary for services at the U.S. Department of Commerce who will focus on negotiations around a new EU-U.S. Privacy Shield or another data transfer mechanism.</p><p>However, the trend to regulate international data transfers isn’t confined to Europe. India’s Personal Data Protection Bill, likely to become law in 2021, would bar certain types of personal data from leaving India. And Brazil’s Lei Geral de Proteção de Dados (**“**LGPD”), which went into effect in 2020, contains requirements for contractual guarantees that need to be in place for personal data to be processed outside Brazil.</p><p>Meanwhile, we’re seeing more data protection regulation across the globe: The California Consumer Privacy Act (“CCPA”) was amended by a new ballot initiative last year. Countries like Japan, China, Singapore, Canada, and New Zealand, that already had data protection legislation in some form, proposed or enacted amendments to strengthen those protections. And even the United States is considering comprehensive Federal data privacy regulation.</p><p>In light of last year’s developments and those we expect to see in 2021, Cloudflare is thinking a lot about what it means to process personal data outside its home jurisdiction. One of the key messages to come out of Europe in the second half of 2020 was the idea that to be able to transfer EU personal data to the United States, data processors would have to provide additional safeguards to ensure GDPR-level protection for personal data, even in light of the application of U.S. surveillance laws. While we are eagerly awaiting the EDPB’s final guidance on the subject, we aren’t waiting to ensure that we have in place the necessary additional safeguards.</p><p>In fact, Cloudflare has long maintained policies to address concerns about access to personal data. We’ve done so because we believe it’s the right thing to do, and because the conflicts of law we are seeing today seemed inevitable. We feel so strongly about our ability to provide that level of protection for data processed in the U.S., that today we are publishing a paper, “<a href="https://www.cloudflare.com/privacy-and-compliance/">Cloudflare’s Policies around Data Privacy and Law Enforcement Requests</a>,” to describe how we address government and other legal requests for data.</p><p>Our paper describes our policies around data privacy and data requests, such as providing notice to our customers of any legal process requesting their data, and the measures we take to push back on any legal process requesting data where we believe that legal process creates a conflict of law. The paper also describes our public commitments about how we approach requests for data and public statements about things we have never done and, in CEO Matthew Prince’s words, that we “will fight like hell to never do”:</p><ul><li><p>Cloudflare has never turned over our encryption or authentication keys or our customers' encryption or authentication keys to anyone.</p></li><li><p>Cloudflare has never installed any law enforcement software or equipment anywhere on our network.</p></li><li><p>Cloudflare has never provided any law enforcement organization a feed of our customers' content transiting our network.</p></li><li><p>Cloudflare has never modified customer content at the request of law enforcement or another third party.</p></li></ul><p>In 2021, the Cloudflare team will continue to focus on these safeguards to protect <i>all</i> our customers’ personal data.</p>
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            <img src="https://cf-assets.www.cloudflare.com/zkvhlag99gkb/4JH1gTlP1F84hlrmh5OUFx/9ceda58d8ba871c492d3db08837b56a4/image4-22.png" />
            
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      <h3>Addressing Data Localization Challenges</h3>
      <a href="#addressing-data-localization-challenges">
        
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    <p>We also recognize that attention to international data transfers isn’t just a jurisdictional issue. Even if jurisdictions don’t require data localization by law, highly regulated industries like banking and healthcare may adopt best practice guidance asserting more requirements for data if it is to be processed outside a data subject’s home country.</p><p>With so much activity around data localization trends and international data transfers, companies will continue to struggle to understand regulatory requirements, as well as update products and business processes to meet those requirements and trends. So while we believe that Cloudflare can provide adequate protections for this data regardless of whether it is processed inside or outside its jurisdiction of origin, we also recognize that our customers are dealing with unique compliance challenges that we can help them face.</p><p>That means that this year we’ll also continue the work we started with our <a href="https://www.cloudflare.com/data-localization/">Cloudflare Data Localization Suite</a>, which we announced during our Privacy &amp; Compliance Week in December 2020. The Data Localization Suite is designed to help customers build local requirements into their global online operations. We help our customers ensure that their data stays as private as they want it to, and only goes where they want it to go in the following ways:</p><ol><li><p>DDoS attacks are detected and mitigated at the data center closest to the end user.</p></li><li><p>Data centers inside the preferred region decrypt TLS and apply services like <a href="https://www.cloudflare.com/learning/ddos/glossary/web-application-firewall-waf/">WAF</a>, CDN, and Cloudflare Workers.</p></li><li><p>Keyless SSL and Geo Key Manager store private SSL keys in a user-specified region.</p></li><li><p>Edge Log Delivery securely transmits logs from the inspection point to the log storage location of your choice.</p></li></ol>
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      <h3>Doubling Down on Privacy-Enhancing Technologies</h3>
      <a href="#doubling-down-on-privacy-enhancing-technologies">
        
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    <p>Cloudflare’s mission is to “Help Build a Better Internet,” and we’ve said repeatedly that a privacy-respecting Internet is a better Internet. We believe in empowering individuals and entities of all sizes with technological tools to reduce the amount of personal data that gets funnelled into the data ocean — regardless of whether someone lives in a country with laws protecting the privacy of their personal data. If we can build tools to help individuals share less personal data online, then that’s a win for privacy no matter what their country of residence.</p><p>For example, when Cloudflare launched the  <a href="/announcing-1111/">1.1.1.1 public DNS resolver</a> — the Internet's <a href="https://www.dnsperf.com/#!dns-resolvers">fastest</a>, privacy-first public DNS resolver — we committed to our public resolver users that we would not retain any personal data about requests made using our 1.1.1.1 resolver. And because we baked anonymization best practices into the 1.1.1.1 resolver when we built it, we were able to demonstrate that we didn’t have any personal data to sell when we asked independent accountants to conduct a <a href="/announcing-the-results-of-the-1-1-1-1-public-dns-resolver-privacy-examination/">privacy examination</a> of the 1.1.1.1 resolver.</p><p>2021 will also see a continuation of a number of initiatives that we <a href="/next-generation-privacy-protocols/">announced</a> during Privacy and Compliance Week that are aimed at improving Internet protocols related to user privacy:</p><ol><li><p>Fixing one of the last information leaks in HTTPS through Encrypted Client Hello (ECH), the evolution of Encrypted SNI.</p></li><li><p>Developing a superior protocol for password authentication, OPAQUE, that makes password breaches less likely to occur.</p></li><li><p>Making DNS even more private by supporting Oblivious DNS-over-HTTPS (ODoH).</p></li></ol>
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      <h3>Encrypted Client Hello (ECH)</h3>
      <a href="#encrypted-client-hello-ech">
        
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    <p>Under the old TLS handshake, privacy-sensitive parameters were negotiated completely in the clear and available to network observers. One example is the Server Name Indication (SNI), used by the client to indicate to the server the website it wants to reach — this is not information that should be exposed to eavesdroppers. Previously, this problem was mitigated through the Encrypted SNI (ESNI) extension. While ESNI took a significant step forward, it is an incomplete solution; a major shortcoming is that it protects only SNI. The <a href="/encrypted-client-hello/">Encrypted Client Hello (ECH)</a> extension aims to close this gap by enabling encryption of the entire ClientHello, thereby protecting <b>all</b> privacy-sensitive handshake parameters. These changes represent a significant upgrade to TLS, one that will help preserve end-user privacy as the protocol continues to evolve. As this work continues, Cloudflare is committed to doing its part, along with close collaborators in the standards process, to ensure this important upgrade for TLS reaches Internet-scale deployment.</p>
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      <h3>OPAQUE</h3>
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    <p>Research has repeatedly shown that passwords are hard for users to manage — and they are also a challenge for servers: passwords are difficult to store securely, they’re frequently leaked and subsequently brute-forced. As long as people still use passwords, we’d like to make the process as secure as possible. Current methods rely on the risky practice of handling plaintext passwords on the server side while checking their correctness. One potential alternative is to use <a href="/opaque-oblivious-passwords/">OPAQUE</a>, an asymmetric Password-Authenticated Key Exchange (aPAKE) protocol that allows secure password login without ever letting the server see the passwords.</p><p>With OPAQUE, instead of storing a traditional salted password hash, the server stores a secret envelope associated with the user that is “locked” by two pieces of information: the user’s password (known only by the user), and a random secret key (known only by the server). To log in, the client initiates a cryptographic exchange that reveals the envelope key only to the client (but not to the server). The server then sends this envelope to the user, who now can retrieve the encrypted keys. Once those keys are unlocked, they will serve as parameters for an Authenticated Key Exchange (AKE) protocol, which establishes a secret key for encrypting future communications.</p><p>Cloudflare has been pushing the development of OPAQUE forward, and has released a reference core OPAQUE <a href="https://github.com/cloudflare/opaque-core">implementation in Go</a> and a demo <a href="https://github.com/cloudflare/opaque-ea">TLS integration</a> (with a <a href="https://opaque.research.cloudflare.com/">running version</a> you can try out). A Typescript client implementation of OPAQUE is coming soon.</p>
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      <h3>Oblivious DNS-over-HTTPS (ODoH)</h3>
      <a href="#oblivious-dns-over-https-odoh">
        
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    <p>Encryption is a powerful tool that protects the privacy of personal data. This is why Cloudflare has doubled down on its implementation of <a href="/dns-encryption-explained/">DNS over HTTPS (DoH)</a>. In the snail mail world, courts have long recognized a distinction between the level of privacy afforded to the contents of a letter vs. the addressing information on an envelope. But we’re not living in an age where the only thing someone can tell from the outside of the envelope are the “to” and “from” addresses and place of postage. The “digital envelopes” of DNS requests can contain much more information about a person than one might expect. Not only is there information about the sender and recipient addresses, but there is specific timestamp information about when requests were submitted, the domains and subdomains visited, and even how long someone stayed on a certain site. Encrypting those requests ensures that only the user and the resolver get that information, and that no one involved in the transit in between sees it. Given that our digital envelopes tell a much more robust story than the envelope in your physical mailbox, we think encrypting these envelopes is just as important as encrypting the messages they carry.</p><p>However, there are more ways in which DNS privacy can be enhanced, and Cloudflare took another incremental step in December 2020 by <a href="/oblivious-dns/">announcing support for Oblivious DoH (ODoH)</a>. ODoH is a proposed DNS standard — co-authored by engineers from Cloudflare, Apple, and Fastly — that separates IP addresses from queries, so that no single entity can see both at the same time. ODoH requires a proxy as a key part of the communication path between client and resolver, with encryption ensuring that the proxy does not know the contents of the DNS query (only where to send it), and the resolver knowing what the query is but not who originally requested it (only the proxy’s IP address). Barring collusion between the proxy and the resolver, the identity of the requester and the content of the request are unlinkable.</p><p>As with DoH, successful deployment requires partners. A key component of ODoH is a proxy that is disjoint from the target resolver. Cloudflare is working with several leading proxy partners — currently PCCW, SURF, and Equinix — who are equally committed to privacy, and hopes to see this list grow.</p>
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            <img src="https://cf-assets.www.cloudflare.com/zkvhlag99gkb/7sNi1Sbcfs9uDZntGHHXQV/638feb2a6ca942f20b6ffafea5686fe1/image2-21.png" />
            
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      <h3><b>Post-Quantum Cryptography</b></h3>
      <a href="#post-quantum-cryptography">
        
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    <p>Even with all of these encryption measures, we also know that everything encrypted with today’s public key cryptography can likely be decrypted with tomorrow’s quantum computers. This makes deploying <a href="https://www.cloudflare.com/learning/ssl/quantum/what-is-post-quantum-cryptography/">post-quantum cryptography</a> a pressing privacy concern. We’re likely 10 to 15 years away from that development, but as our Head of Research Nick Sullivan described in his <a href="/securing-the-post-quantum-world/">blog post in December</a>, we’re not waiting for that future. We’ve been paying close attention to the <a href="https://csrc.nist.gov/Projects/Post-Quantum-Cryptography">National Institute of Standards and Technology (NIST)</a>’s initiative to define post-quantum cryptography algorithms to replace RSA and ECC. Last year, Cloudflare and Google performed the <a href="/the-tls-post-quantum-experiment/">TLS Post-Quantum Experiment</a>, which involved implementing and supporting new key exchange mechanisms based on post-quantum cryptography for all Cloudflare customers for a period of a few months.</p><p>In addition, Cloudflare’s Research Team has been working with researchers from the University of Waterloo and Radboud University on a new protocol called <a href="/kemtls-post-quantum-tls-without-signatures/">KEMTLS</a>. KEMTLS is designed to be fully post-quantum and relies only on public-key encryption. On the implementation side, Cloudflare has developed high-speed assembly versions of several of the NIST finalists (Kyber, Dilithium), as well as other relevant post-quantum algorithms (CSIDH, SIDH) in our CIRCL cryptography library written in Go. Cloudflare is endeavoring to use post-quantum cryptography for most internal services by the end of 2021, and plans to be among the first services to offer post-quantum cipher suites to customers as standards emerge.</p>
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      <h3>Looking forward to 2021</h3>
      <a href="#looking-forward-to-2021">
        
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    <p>If there’s anything 2020 taught us, it’s that our world can change almost overnight. One thing that doesn’t change, though, is that people will always want privacy for their personal data, and regulators will continue to define rules and requirements for what data protection should look like. And as these rules and requirements evolve, Cloudflare will be there every step of the way, developing innovative product and security solutions to protect data, and building privacy into everything we do.</p>
    <div>
      <h3>Watch on Cloudflare TV</h3>
      <a href="#watch-on-cloudflare-tv">
        
      </a>
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            <dc:creator>Emily Hancock</dc:creator>
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