Contrary to popular belief, the issue of sovereignty is not limited to concerns about the U.S. Cloud Act; it is primarily about having effective control over one’s data and digital infrastructure.

Practically, a sovereign cloud should adhere to four fundamental principles:

1. Data residency

Know where your data is stored and ensure it complies with the laws of the chosen territory.

2. Access control

Manage who can access your information and under what conditions.

3. Security and resilience

Benefit from robust protections against cyber threats and ensure business continuity.

4. Reversibility

Be able to retrieve your data and switch providers without technological dependence.

A similar reality in Canada

It is important to put the Cloud Act into perspective relative to the equivalent powers held by Canadian authorities. In reality, Canada’s mechanisms for accessing data are not fundamentally different from those under the Cloud Act.

In Canada, law enforcement can already:

• Obtain search warrants for digital data: Under section 487 of the Criminal Code, peace officers can obtain warrants to search and seize computer data, including the use of any computer at a location to verify data it contains or provides access to. 
• Request disclosure of data: The Privacy Act provides exceptions allowing disclosure of personal information “required by subpoena, warrant, or court order” or “to a designated investigative body for the enforcement of federal or provincial laws.” 
• Access data without prior notice: Similar to the Cloud Act, the Canadian system allows warrants to be executed without immediate notification to the individuals concerned, especially in national security investigations. 
• Preserve data: The Canadian Anti-Cybercrime Act allows orders to preserve computer data, requiring service providers to retain certain data for a specified period.

Protections are similar:

• Both systems require judicial authorization to access data 
• Both provide mechanisms for challenging requests 
• Both include protections against abusive requests 
• Both allow service providers to challenge non-compliant requests 

In essence, if your Quebec business hosts its data with a Canadian provider, it remains subject to the same types of government requests as with a U.S. provider operating under the Cloud Act. The difference lies not in the existence of these powers, but in the jurisdiction exercising them.

Protection against outages and incidents

In 2021, 52% of micro, small, and medium enterprises were victims of ransomware attacks. A sovereign cloud architecture offers guarantees of resilience and recovery of critical data for business continuity.

Simplified regulatory compliance

Non-compliance with regulations such as GDPR can lead to significant financial penalties. A sovereign cloud facilitates compliance by providing clear guarantees on data location and processing.

Technological independence

A commercial monopoly that allows prices to double or quintuple during contract renewal is equally a threat to sovereignty. True sovereignty includes the ability to switch providers without economic coercion.

Multi-region Canadian architecture

Available AWS regions in Canada:

• Canada Central (ca-central-1): Montreal region with 3 availability zones 
• Canada West (ca-west-1): Calgary region with 3 availability zones 

This bi-regional configuration allows Quebec businesses to:

• Maintain high availability with automatic failover between regions 
• Comply with data residency requirements by keeping everything in Canada 
• Optimize latency for users in both western and eastern Canada 
• Implement a robust disaster recovery strategy

AWS Control Tower: Automated governance

AWS Control Tower offers data residency guardrails that can be configured specifically for Canada:

Recommended configuration:

1. Regional restriction: Enable “Region Deny” to automatically block deployment outside Canadian regions
2. Automatic monitoring: Deploy detection rules that alert in case of non-compliant resource creation
3. Preventive policies: Implement Service Control Policies (SCPs) to prevent:
   • Replication of data to non-Canadian regions
   • Creation of unauthorized internet gateways
   • Use of services incompatible with data residency

Advantages for SMEs:

• Automated configuration: No deep technical expertise required
  
• Continuous compliance: 24/7 automated monitoring
  
• Controlled costs: No extra fees for guardrails (only underlying services are billed)

Advanced encryption with AWS KMS and External Key Store (XKS)

For SMEs with strict sovereignty requirements, AWS offers advanced encryption options:

Option 1 : AWS KMS with customer-managed keys

• Encryption keys generated and stored in AWS HSMs in Canada
  
• Full control over access and key rotation
  
• Compatible with over 100 AWS services

Option 2 : External Key Store (XKS)

• Encryption keys stored completely outside AWS
  
• Canadian partners available (including solutions with Thales and Atos)
  
• “Hold Your Own Keys” (HYOK) model for maximum sovereignty

Private network and isolation

Sovereign VPC configuration:

• Private VPC in Canadian regions only
  
• Private subnets without direct internet access
  
• VPN or Direct Connect for secure connectivity
  
• VPC endpoints to access AWS services without internet transit
  
• Flow logs to monitor all network traffic

Network checkpoints:

• All data flows remain within Canadian infrastructure
  
• Automatic encryption of all inter-region communications
  
• Real-time monitoring of unauthorized connections

Continuous monitoring and audit

 Automated compliance tools:

• AWS CloudTrail: Audit all API actions
  
• AWS Config: Monitor resource configuration
  
• AWS Security Hub: Centralized security dashboard
  
• AWS GuardDuty: Detect suspicious activity

How to choose the right approach?

For beginner SMEs:

• Start with Canadian regions and AWS Control Tower
  
• Use standard AWS KMS encryption with customer-managed keys
  
• Gradually implement data residency guardrails

For SMEs with strict requirements:

• Multi-region architecture: Canada Central + Canada West
  
• External Key Store (XKS) with Canadian HSM
  
• Fully private VPC with continuous monitoring

Cost assessment:

• AWS KMS: $1/month per key (same for XKS)
  
• Control Tower: Free (only underlying services are billed)
  
• Monitoring: AWS Config ~ $0.003 per rule per region

Their commitments include:

• Control of data location: Clients control where their data is stored, with eight regions currently available in Europe

• Verifiable access control: AWS Nitro hardware and specialized software protect data from external access

• Universal encryption: All AWS services already support encryption, most with customer-managed keys inaccessible to AWS

Whether with AWS, Microsoft Azure, Google Cloud, or European alternatives like OVHcloud, the important thing is to maintain control over your digital assets.

At Unicorne, we support Quebec businesses in this process by favoring architectures that combine performance, security, and sovereignty. Because your digital autonomy is the key to your future success.