Hi @Andrei B,
As per the official Microsoft documentation, when you create an ACS resource, you choose a geography (e.g., “Europe”), not a specific data center. So, yes, if you provision the ACS resource in Europe, the underlying storage and service data (emails, metadata, etc.) will reside within European data centers, compliant with EU data residency rules.
You're correct that Event Grid system topics used by ACS (such as for email deliverability events) are managed in a global scope. This is clearly stated in the documentation: https://learn.microsoft.com/en-us/azure/communication-services/concepts/privacy#event-handling This global configuration helps Microsoft ensure high availability and delivery guarantees for events like bounces, opens, or delivery status.
The system topic is global, but the Event Grid destination (your handler) is under your control. Microsoft may temporarily process event data globally (for routing and delivery), but once it's delivered to your Azure Event Grid resource, you control where the data is processed/stored. Email delivery events typically contain metadata like: The recipient’s email address, Event type (e.g., Delivered, Bounced, Opened), Message identifiers, Timestamps. Yes, email addresses are considered PII under GDPR, so their handling must comply with EU laws.
To ensure EU residency for all data under your control, we recommend the following:
- Provision the ACS resource in a European geography: E.g., “West Europe” or “North Europe” https://azure.microsoft.com/en-us/explore/global-infrastructure/products-by-region/?products=communication-services
- Use Azure Event Grid Custom Topics or Event Subscriptions hosted in a European region. This ensures once events are pushed from the global system topic, they're routed to an EU-hosted Azure resource like Azure Function, Logic App, Storage Queue https://learn.microsoft.com/en-us/azure/event-grid/overview#availability-and-regions
- Make sure your event handler filters and minimizes data storage. Apply data masking or encryption if needed. Follow best practices for PII handling: https://learn.microsoft.com/en-us/azure/security/fundamentals/protection-customer-data
- If you’re especially concerned about data movement, use Private Link to connect to Event Grid, Secure endpoints to allow traffic only within the Azure backbone network Learn more on Event Grid security
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