“We want the flexibility of cloud, but we need to comply with data sovereignty regulations.”

I hear this line from CTOs and IT leaders across Africa all the time. And while it captures part of the challenge, it misses the core of the issue.

As the Chief Legal Officer and Head of Partnerships at Deimos, my job often involves translating complex legal obligations into practical solutions and helping engineering teams build systems that don’t just perform, but comply. And here’s the uncomfortable truth: the real challenge isn’t choosing between cloud agility and data sovereignty. It’s understanding ‘what the laws actually require’, and more importantly, ‘how to build systems using cloud-native patterns that meet those requirements without jeopardising performance’.

Yes, we all know that keeping some data on-premises can help with compliance. What most organisations quickly discover is that connecting those local systems to globally distributed cloud environments, securely, reliably, and legally, is anything but straightforward.

Let’s unpack what the laws really mean, why hybrid cloud is the most realistic path forward, and why getting it right is so difficult without a legal-technical partnership like the one we offer at Deimos.

The Regulatory Landscape: Diverse, Evolving, and Not Always Clear

Across Africa, governments are racing to define how citizens’ personal data should be handled in the age of cloud computing. Unfortunately, these laws aren’t uniform. Each country brings its own interpretation of data sovereignty, and each demands different technical and contractual responses.

Let me walk you through the major frameworks shaping the data compliance terrain:

1. South Africa - POPIA

The Protection of Personal Information Act is a mature data protection law that requires organisations to process personal data responsibly, with consent, and within clear boundaries. It also restricts cross-border transfers unless:

• The receiving country has equivalent protections, or
• The data subject consents, or
• Adequate contractual safeguards are in place (like binding corporate rules or standard clauses).

2. Nigeria - NDPR

The Nigeria Data Protection Regulation mandates that data collected in Nigeria be stored locally unless:

• Adequate protections exist in the destination country, or
• The data subject consents to the transfer.

Enforcement is ramping up, and fines for violations are no longer theoretical.

3. Kenya - Data Protection Act (DPA) 2019

Kenya’s law prohibits the transfer of personal data across borders unless specific legal mechanisms are in place. These include:

• Adequacy decisions
• Standard data protection clauses
• Express, informed user consent

It also requires that data controllers register with the Data Protection Commissioner and maintain detailed audit logs.

4. Egypt - Data Protection Law No. 151 of 2020

This is arguably the most stringent data protection law in the region. It:

• Requires a license from Egypt’s Data Protection Centre before any data is transferred abroad
• Forbids export of personal data unless the destination country offers equal or stronger protections
• Introduces criminal penalties for violations, not just administrative fines

The bottom line? Compliance isn’t a one-size-fits-all proposition. If you operate in multiple African countries, your architecture must adapt to a patchwork of regulations. The laws may all wave the banner of “data sovereignty,” but how that plays out in practice - what you can store where, how you can process it, and under what conditions - differs widely.

This is where the complexity starts.

The Real-World Challenge: It’s Not About the Server Location

Here's where the conversation gets real. Most data laws don’t just care where your server is. They care about who can access the data, how it’s secured, how it’s moved, and what legal frameworks support those processes.

So, even if your data is stored in-country in your hyperscaler’s local region, it may be processed in another region if the particular service you’re using isn’t available in your region. If this is the case compliance has to be assessed against your local data protection laws, and it needs to be assessed whether the data is now subject to laws in another country.

It’s not enough to point to a South African data centre or a private rack in Nairobi and say, "we’re compliant." You need:

• De facto knowledge of the region within which the service is hosted/executed
• Contracts that define who controls and accesses the data
• Technical safeguards like encryption and audit logs
• Proof that users have consented to how their personally identifiable data is being used

In short, compliance is not a location; it’s a process.

The Technical Solution: Hybrid Cloud (But With Caveats)

This is where many CTOs are landing: "Let’s deploy a hybrid solution." And on paper, hybrid cloud is the ideal solution:

• You keep sensitive or regulated data on-prem or in-country
• You use public cloud to scale, innovate, and modernise
• You integrate the two environments so they work together in real time

But here’s the problem: doing this well is extremely complex. Especially in Africa, where cloud and telecommunications infrastructure are unevenly distributed.

The Infrastructure Gaps Are Real

Here’s what we’re seeing in the field:

1. Lack of Local Cloud Regions

Very few African countries have access to true local data regions from hyperscalers. While South Africa has local regions for AWS, Google Cloud, Azure, and Huawei Cloud, this is not true for major economies like Nigeria, Egypt, Ghana, or Kenya who often route traffic to Europe or the Middle East. If they’re lucky a hyperscaler might have a point-of-presence (POP) or edge location in-country, but these do not materially contribute to compliance because all the services touching the protected data are not in-country.

So for most African businesses full data localisation is in direct conflict with being fully deployed in the cloud. Protected data needs to be physically hosted in-country.

2. Performance, Latency and Constraints

The answer is obviously a hybrid-cloud deployment. However, not all hybrid cloud deployments are equal. When done incorrectly, connecting on-prem and cloud workloads introduces latency. For customer-facing applications (think digital banking, healthcare, or e-commerce), even small delays can be unacceptable.

Costs are another concern worth noting. Hybrid architectures typically involve continuous data transfer between on-premise systems and the cloud. This means organisations are more likely to incur significant ingress and egress charges associated with networking. Over time, these hidden costs can rival - or even exceed - the savings and scalability benefits that hybrid models promise if not carefully managed.

3. Integration Complexity

There’s no off-the-shelf way to connect public cloud workloads with local systems securely and efficiently. It requires:

• Network engineering
• Security enforcement across environments
• Unified identity and access management
• Real-time observability

What Hybrid Actually Looks Like (When It Works)

Let’s look at how it can work in practice.

Example 1: GCP + On-Prem in Egypt

A Cairo-based logistics platform needs to keep customer identity data in Egypt but wants to use Google Cloud Platform for its analytics stack.

Solution:

• Personal data is stored on-prem in Cairo
• Analytical data is pseudonymised and synced to BigQuery via a secure, monitored pipeline
• GCP's Anthos is used as a hybrid/multi-cloud management layer, enabling Kubernetes-based orchestration across on-prem, edge, and other clouds. 
• Deimos configures custom data classification, access policies, and legal contracts to meet Egypt’s licensing requirements

Example 2: AWS + Outposts in Nigeria

A Nigerian payments company needs to comply with NDPR but still leverage AWS-native services.

Solution:

• Deploy AWS Outposts inside Nigeria for local data storage and processing
• Use Cape Town region (NDPR equivalent) for less sensitive compute tasks
• Deimos configures encryption-in-use, IAM policies, and audit logs to enforce data segmentation

Why Most CTOs Struggle to Implement This

Let me be clear: most CTOs know what they need to do in principle. But it is hard to get it right in practice:

• Lack of internal expertise: Hybrid systems need deep networking, infrastructure, security, and compliance skills
• Vendor complexity: Each provider has different capabilities and limitations in Africa
• Fear of non-compliance: Getting it wrong has legal and reputational consequences
• Cost of experimentation: Trial-and-error is expensive, both in money and time

That’s where Deimos’ work starts

How Deimos Makes Hybrid Work in Africa

At Deimos, we help our clients bridge the gap between regulation and innovation. Here’s how:

1. Regulatory-Aligned Cloud Architecture

We design systems that work with your specific legal obligations. We don’t guess. We build with:

• Country-specific compliance controls
• Proven frameworks like AWS Outposts, GCP Anthos etc
• Enterprise grade secrets management systems like HashiCorp Vault 
• Comprehensive policy enforcement tools Cloudflare

2. Secure Integration Between Cloud and On-Prem

We manage:

• Identity federation
• Secure VPN/Interconnect
• Policy-based routing
• Monitoring and logging

3. Ongoing Optimisation and Managed Support

Hybrid isn’t a one-time setup. We:

• Tune for latency and throughput
• Test failover and DR scenarios
• Keep you compliant as laws evolve

We offer this under our Managed Platforms and Professional Services teams.

In Closing: Don’t Wait for an Audit to Take Action

Africa’s regulatory environment is maturing. Audits are becoming more common. And the cost of getting this wrong - legally, financially, reputationally - is rising fast.

Hybrid cloud is not a buzzword. It’s the operational reality for any serious business working across multiple African jurisdictions.

And getting it right requires more than engineers or lawyers. It requires both. That’s what we do at Deimos.

Ready to make your hybrid cloud strategy real?Let Deimos help with a tailored Cloud Assessment or Cloud Modernisation plan. Click here to speak to our experts today.