Who really owns your customer data? A marketer's guide to digital independence

In my previous article on digital sovereignty, I explored the overarching concept of how organisations can maintain control over their entire digital ecosystem. Today, I want to focus specifically on data sovereignty - arguably the most critical aspect of digital sovereignty for marketers, and the one that impacts businesses of every size, from solo entrepreneurs to global enterprises.

This article is part of a series exploring digital sovereignty in marketing technology. If you missed the first article on the broader concept of digital sovereignty, I recommend starting there for context before diving into the specifics of data sovereignty.

What is data sovereignty, and how does it differ from digital sovereignty?

While digital sovereignty encompasses control over your entire digital presence - including infrastructure, software, and governance - data sovereignty focuses specifically on your most valuable asset - your data.

Data sovereignty is where the rubber meets the road for marketers - it’s about where your data physically lives, who can access it, how it can be used, and crucially, which laws apply to it based on its location.

For marketers, this couldn’t be more important. Every day, we collect, analyse, and act upon customer data that drives our campaigns, informs our strategies, and builds our relationships. But how many of us can confidently answer these questions:

• Do you know exactly which countries your customer data is stored in?
• Are you aware of which legal jurisdictions have authority over that data?
• Can you access and export your complete customer dataset (not just contacts and company, but all their activity data, too) if needed?
• Do you control how your data is processed and used?

If you’re hesitating on any of these questions, you’re not alone - and that’s precisely why we need to talk about data sovereignty.

Why data sovereignty matters: different stakes for different business sizes

The small business perspective

For small businesses, data sovereignty often feels like a ‘big company problem.’ After all, when you’re wearing multiple hats and stretching limited resources, worrying about where your marketing data physically resides seems somewhat abstract compared to generating leads and making sales.

Small businesses, however, actually have the most to lose from ignoring data sovereignty (and trust me, I know this first hand and have directly felt the pain myself!)

When I was building my first email marketing list years ago, I chose a popular ‘free’ email marketing tool. It wasn’t until I needed to migrate to a more sophisticated platform that I discovered the harsh reality: I couldn’t export my subscribers’ engagement history - only their basic information. Months of valuable data about which content resonated with my audience was effectively held hostage. 

Small businesses also, in my experience, tend to need to move marketing tools more often.

You might not always know what you want when you first start dipping a toe into marketing.

You may think you’ll be fine with 500 contacts, but then you have a great trade show and suddenly you’re faced with a big bill to keep using the tool that was pitched as free and convenient for small business. What’s more, now you fear moving elsewhere because the lack of portability of your data combined with the time it’s going to take to rebuild that customer dataset elsewhere means it’s going to be a painful process, so you just cough up the extra money to stay where you are, which just wiped out any profit from your growth.

For small businesses, data sovereignty issues manifest in practical ways:

• Limited ability to switch marketing tools without losing valuable data
• Unexpected changes to terms of service that affect how you can use your data
• Potential exposure to foreign laws that could compromise customer privacy
• Difficulty complying with regulations when you don’t fully control your data

Even with limited resources, small businesses can take meaningful steps toward data sovereignty, which we’ll cover shortly.

Mid-market challenges

Mid-sized businesses face a more complex data sovereignty landscape. Their marketing technology stacks have typically grown into a sprawling, sometimes weed-infested garden including multiple tools - email platforms, CRMs, analytics solutions, advertising tools, social media managers - each with its own data practices and storage locations.

This fragmentation creates significant data sovereignty challenges:

• Inconsistent data governance across different platforms
• Difficulty tracking where all customer data resides
• Compliance complexity when different tools follow different standards
• The hidden costs of maintaining and reconciling data across systems

For mid-market businesses, data sovereignty is as much about efficiency as it is about control. When your customer data is fragmented across tools with varying levels of data portability, you waste valuable time and resources just trying to create a unified view of your customers and moving data between tools.

I’ve worked with several growing businesses in the past that discovered they were paying many times over for customer data management - once for the various tools that collected the data, again for integration platforms to connect them all due to a lack of built-in connectivity, and a third time in staff hours spent reconciling conflicts and gaps.

Enterprise-level implications

For enterprises, data sovereignty takes on strategic importance beyond mere compliance. Large organisations face:

• Substantial regulatory exposure across multiple jurisdictions
• Significant financial risks from potential fines, often based on % turnover
• Complex vendor landscapes with varying data sovereignty standards
• Strategic disadvantages when competitors have better data control

It’s not unheard of for an audit to discover that customer data was being processed in 10+ different countries - several of which probably have laws allowing government access without notification. This can create not just compliance risks but potential competitive disadvantages if sensitive information about their marketing strategy or customer base were to be compromised.

For enterprises, data sovereignty is fast becoming a strategic imperative that affects everything from regulatory compliance to competitive positioning.

The marketing technology stack

Marketing technology presents unique data sovereignty challenges because it’s so fundamental to customer relationships. Let’s examine common sovereignty weak points in the typical marketing stack:

Email marketing platforms

Many popular email marketing tools store data in regions subject to laws like the US CLOUD Act, which allows American authorities to compel US-based companies (or any company from anywhere in the world which has a physical base in US territory) to provide data regardless of where it’s physically stored. This creates a data sovereignty conflict with regulations like GDPR.

CRM systems

Customer relationship management systems often become central repositories of valuable data, but many offer limited export capabilities, creating lock-in that undermines data sovereignty. I’ve seen organisations trapped with outdated CRM systems simply because extracting their complete customer history was nearly impossible, and their business would be severely impacted without it.

Marketing automation

Automation platforms typically have deep access to customer behaviour data across multiple channels. This creates significant data sovereignty implications when these platforms are cloud-based and store your automation rules, segments, and engagement data on their servers, rather than yours, or in countries that don’t align with your corporate values when it comes to data sovereignty.

Analytics solutions

Web analytics tools collect detailed information about how users interact with your digital properties. Many popular solutions transmit this data to servers in jurisdictions that may have conflicting privacy frameworks with your own country’s laws.

Advertising platforms

The advertising ecosystem is particularly challenging for data sovereignty because data often flows through multiple intermediaries before reaching its destination. Many marketers have limited visibility into where their customer data goes after it enters the advertising ecosystem.

Practical steps to improve data sovereignty in your marketing

While this might seem like a bit of a scary, daunting thing to address, there are practical steps that you can take in order to improve data sovereignty in your marketing operations.

Audit your marketing technology stack

Start by creating a comprehensive inventory of all the tools you use to collect, store, or process customer data. For each tool, document:

• Where data is physically stored (which countries) 
• What types of data are collected
• Whether complete data export is possible
• Which regulations apply to data in those locations

It is likely that you already have some of this put together if you’re a Data Controller for the purposes of complying with the GDPR. If you don’t yet have it, I recommend creating a simple spreadsheet with these columns, as the exercise often reveals surprising gaps in knowledge about your marketing data.

Develop a data portability strategy

For each critical marketing system, develop a clear understanding of how you would extract your data if needed, and where you’d migrate to if your tool stopped working. This includes:

• Testing export capabilities to ensure they work as expected
• Documenting the format and completeness of exported data
• Identifying potential destination systems for data migration
• Establishing regular data backup procedures for critical information, outside of the infrastructure of your current tool (and in a location you own)

It’s not just a theoretical exercise that you do once and then sits on a shelf, I really recommend you try once a year, even if it’s just a ‘dry run’, to migrate from your current system to another system and see what the gaps are in your data and your processes. It’s sometimes been the case that organisations have had to migrate from their marketing automation platform with just 30 days’ notice when their vendor was acquired. Having a data portability strategy in place made a chaotic situation manageable.

Consider open source alternatives in your procurement processes

Open source marketing tools offer a compelling path to data sovereignty because they can be self-hosted or deployed with hosting providers in your preferred jurisdiction. This gives you full control over where your data resides and how it’s protected.

Tools like Mautic for marketing automation, Matomo for analytics, and other open source marketing technologies allow you to maintain control of your data while still accessing sophisticated marketing capabilities.

I’ve seen organisations of all sizes benefit from adopting open source marketing technologies, from solo entrepreneurs who value the control and cost-effectiveness to enterprises that appreciate the ability to modify and extend these tools to meet their specific requirements.

Ask the right question of vendors

When evaluating new marketing technology vendors, ask pointed questions about data sovereignty:

• Where exactly will our data be stored?
• Which jurisdictions and laws will apply to our data?
• Can we specify data storage locations to meet our regulatory requirements?
• What is your process for responding to government data requests?
• How complete is your data export functionality?
• What happens to our data if we terminate the service?

The answers to these questions should be documented and factored into your decision-making process.

The data sovereignty checklist for marketers

To assess your current level of data sovereignty, ask yourself these critical questions:

• Can you export ALL your data? Not just basic information, but the complete dataset including historical interactions, custom fields, and derived insights
• Do you know exactly where your data is stored? Not just ‘in the cloud’ but the specific countries and jurisdictions where it physically resides
• Can you modify how your data is used? Do you have control over processing, retention, and usage policies, or are you bound by the vendor’s standard practices?
• Are you reliant on a single vendor’s ecosystem? Having all your marketing technology from one provider might seem convenient but often creates significant sovereignty risks.
• Do you have direct database access when needed? For critical marketing systems, direct database access can be essential for data sovereignty.
• Are your terms of service stable and favourable? Frequent changes to terms that govern your data usage can undermine sovereignty.

Taking control of your marketing data

Data sovereignty is about maintaining practical control over your most valuable marketing asset: your customer data. By taking deliberate steps to improve data sovereignty, marketers of all sizes can build more resilient, compliant, and effective marketing operations.

In my experience helping organisations implement Mautic and other open source marketing technologies, I’ve seen firsthand how liberating it can be to regain control over marketing data. Teams become more innovative when they’re not constrained by vendor limitations, compliance becomes simpler when data storage is transparent, and customer relationships improve when data isn’t fragmented across disconnected systems.

Each step you take toward greater control of your marketing data builds resilience and capability within your organisation.

In my next article, I’ll explore the concept of digital colonialism in marketing technology and introduce the Sovereignty Spectrum - a framework for assessing your current level of digital independence and planning a path toward greater self-determination.

What steps have you taken to improve data sovereignty in your marketing operations? I’d love to hear your experiences in the comments below.