Schrems II compliance of Sanity's CDN for procurement processes in EU
For EU procurement processes, the classification depends on your contractual relationship and how you're using Sanity:
In most cases, Sanity is the Cloud Service Provider (CSP), not Google Cloud. Here's why:
- Sanity is the data controller/processor you contract with directly for content management services
- Google Cloud Platform is Sanity's subprocessor - they provide the underlying infrastructure where Sanity hosts your data
- From a procurement perspective, your contract is with Sanity, and Sanity is responsible for the service delivery
Key points for EU procurement:
Data Residency: Sanity offers EU data residency with Belgium as a primary location for the Content Lake. You can configure your project to store data in EU regions.
GDPR Compliance: Sanity is GDPR-compliant and provides:
- A Data Processing Agreement (DPA)
- Standard Contractual Clauses for data transfers
- A list of subprocessors (which includes Google Cloud Platform)
Security & Compliance: Sanity maintains security certifications including ISO and SOC 2, which are often required for procurement.
Subprocessor Transparency: In your procurement documentation, you should note:
- Primary CSP: Sanity AS (Norwegian entity) / Sanity US Inc.
- Infrastructure subprocessor: Google Cloud Platform
- Data location: EU (Belgium) when configured
For procurement documentation, classify it as:
- Main vendor/CSP: Sanity
- Infrastructure provider: Google Cloud (as subprocessor)
- Data processing location: EU/Belgium (when configured)
This is the standard model for SaaS platforms - similar to how you'd classify Salesforce as the CSP even though they use AWS/their own infrastructure underneath.
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