The Finnish Ministry of Justice’s project to modernize the national electoral system is an important step forward. As Finland continues to digitalize its core public services, the choice of Amazon Web Services (AWS) as the platform for this critical system merits a serious public discussion. This is the first time in history when this level of sensitive and personal data is stored outside of the Finland borders.

The decision to build this system on a non-European cloud platform raises fundamental questions about data sovereignty.

A key consideration, jurisdiction, not location

This conversation is not about the physical location of data centers. It is about jurisdiction.

Data hosted within Finland’s borders, if managed by a US-based provider like AWS, remains subject to the extraterritorial reach of US jurisdiction. The issue arises most notably from the US CLOUD Act, which permits US authorities to request access to data managed by US-based providers, regardless of the location of the data. Such legal backdoor creates a direct conflict with European privacy laws like GDPR and undermines the digital sovereignty of Finland.

For a system as sensitive as a national electoral registry, this jurisdictional ambiguity is a significant strategic consideration. It highlights a need for a clear national policy on how we manage our most critical data. Finland’s national public broadcasting company, YLE, interviewed Researcher Harri Hursti on this topic, where he stated that “National security matters should not be done in a public cloud service”.

It is also notable that even though the backup system is located in a datacanter in Espoo, it is operated by Vivicta, which is a company owned by British-based private equity investor Agilitas and its funds.

An opportunity for strategic alignment

This discussion is timely. Across Europe, and particularly in the Nordic region, there is a growing consensus on the need for digital resilience. As recent ministerial meetings have highlighted, strengthening our own regional capabilities is a shared strategic goal.

This moment provides an opportunity for Finland to lead, ensuring our procurement decisions for critical infrastructure align with this vision of a resilient and sovereign European digital future. 

A matter of platform, not implementation

It is important to clarify that this discussion is about the strategic platform choice. It is not a critique of the technical implementation. Finland is home to world-class technology partners who are experts at building secure and modern public systems.

The underlying question is one of national strategy: which platforms are appropriate for which data?

 

The value of the European cloud

As a Finnish-led, European cloud provider, we are naturally strong proponents of data sovereignty. This principle is at the core of our foundation and our purpose.

A European cloud provides a clear answer to the jurisdictional question. Cloud providers like UpCloud offer the high performance and reliability needed for critical systems, with the essential guarantee that data remains governed exclusively by European law, safe and secured.

We have several clients who (even on top of EU sovereign requirements) rely for critical data from Finland on Finnish Data Centers only due to geographical and physical risk involved.

Diesl research group, which is a collaboration of Aalto University and University of Oxford highlights how “Today’s economies are critically dependent on transnational digital infrastructures and platforms.” and also seeing risk in this kind of geopolitical expansion: “We believe that transformations in digital infrastructures have far-reaching consequences, because in a digitized society computational power translates to political power.”

A call for conversation

Modernizing Finland’s public services is essential. This project is a catalyst for an important national conversation.

We believe it is time for a clear, forward-looking national strategy that defines how and where Finland’s critical data should be hosted, ensuring our digital modernization is built on a foundation of true data sovereignty.

Build on a sovereign foundation

UpCloud is committed to being a partner in this conversation.

If you are developing critical infrastructure or discussing your organization’s data strategy, contact our team to learn how a truly European cloud platform ensures your data remains secure and sovereign.

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