Sovereignty · Dr Ognjen Vučurević · 2026-05-30

GDPR Art. 28 and local inference

When AI inference runs locally, there is no third party processing the data, so the GDPR Article 28 processing-agreement obligation falls away. Data that never leaves your network cannot leak at a processor.

GDPR Article 28 governs the relationship with a “processor” — a third party that processes data on your behalf. Cloud AI is typically such a processor. Local inference simply removes that relationship.

What that means concretely

  • No cross-border data transfer
  • No processor to contract and audit
  • A smaller risk surface for sensitive data

For organizations with sensitive data — healthcare, the public sector — this isn't cosmetics, it's risk mitigation built into the architecture.

Note: this is general information, not legal advice; your DPO or legal team confirms specific compliance.

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