D Docent

Trust & Security

How Docent handles your data — what we store, where we store it, who can see it, and the standards we follow.

Last updated: 17 September 2026

CSA STAR Level One badge
CSA STAR Level One — Self-Assessment ✓ Verified · Listed in the CSA STAR Registry
Docent is publicly listed in the Cloud Security Alliance STAR Registry, self-assessed against the CAIQ v4.0.3 questionnaire covering 17 control domains — cryptography, IAM, data protection, incident response, and more.
cloudsecurityalliance.org/star/registry/docent/services/docent-digital
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Where your data lives

Storage is in Helsinki, Finland. Uploaded documents, the database, search vectors and backups are held on dedicated servers at Hetzner Online GmbH. This is where your data sits at rest.

An EU provider is available on request. Processing is inside the EU either way, but Google is a US company and therefore reachable under the CLOUD Act. An organisation that needs the provider itself to be under EU jurisdiction can switch its answers to Mistral, in France, from its own settings. Two things that switch does not change, stated plainly: search indexing still uses Google's embedding models in EU regions, because changing that would mean re-indexing every document; and storage stays in Helsinki.

AI processing is in the EU. Model calls go to Google Vertex AI, in the EU multi-region or europe-west4 (Eemshaven, Netherlands) — never the global endpoint, which carries no residency guarantee. Google Cloud's EU Data Boundary commitment confines that processing to EEA regions.

Connected systems stay yours. Where you connect SharePoint, OneDrive, Confluence, Nextcloud, Google Drive, Notion or Slack, the original files stay where they are. Docent holds the extracted text, search vectors and the link needed to cite the document — not a copy of the file. Those connections are read-only: nothing in your systems is changed. Microsoft and Atlassian are not sub-processors of Docent in this arrangement; they are your own systems, under your own agreements, reached with an approval your administrator grants and can withdraw at any time.

Your access rules travel with the documents. A SharePoint library or a Confluence space can be synced with its own permissions, so someone who cannot open a file there does not receive it in an answer either — administrators included. Where the permissions cannot be resolved to people, the document is withheld from answers rather than guessed at.

Stored data does not leave the European Economic Area. US companies in the table below: Google (language model and embeddings in EU regions, and reCAPTCHA on sign-in), Sentry (error reports without request content, EU region), Stripe (billing only) and Cloudflare, which serves the marketing website only. The application at app.docent.digital is served directly from Helsinki, so Cloudflare never sees documents, questions or answers.

AI & model training

Your data is never used to train AI models. Docent uses Google Cloud Vertex AI as its model provider. Under Google Cloud's Cloud Data Processing Addendum and the AI/ML Privacy Commitment, prompts and responses are not retained by default and are not used to train or improve any model.

This is enforceable as a processor obligation under Article 28(3) GDPR.

EU AI Act position

Docent is classified as Minimal Risk under Regulation (EU) 2024/1689 (the EU AI Act). A B2B knowledge-management and document Q&A tool does not appear in any Annex III high-risk category, and Docent triggers none of the Article 5 prohibited practices.

What applies to Docent and how we comply:

ProvisionIn forceOur status
Article 4 — AI literacyFeb 2025Covered: our own product helps customers do this
Article 50(1) — Chatbot disclosureAug 2026B2B "obvious to a reasonably informed user" exception applies
Article 50(2) — AI-generated content markingIn force Aug 2026Signatory to the Commission's adequate Code of Practice (recognised compliance pathway); AI outputs carry machine-readable transparency metadata
Annex III high-risk obligations—Not triggered (knowledge management is not listed)
Article 22 GDPR — automated decisions—Not triggered (no decisions producing legal effects on individuals)

Sub-processors

ProviderPurposeLocation
Hetzner Online GmbHHosting, database, document and vector storage, backupsHelsinki, Finland
Google Cloud PlatformVertex AI (Gemini) — model inference and embeddingsEU multi-region / europe-west4 (Netherlands)
Cloudflare, Inc.DNS for our domains, and TLS and denial-of-service protection for the marketing website docent.digital only. The application (app.docent.digital) is not routed through Cloudflare, so no customer documents, questions or answers pass through it; content is not stored.United States (network: nearest data centre, normally in the EU/EEA)
Google (reCAPTCHA Enterprise)Bot protection on the sign-in and sign-up forms: IP address and browser signals, never passwords or document content.Google infrastructure (US parent)
Sentry (Functional Software, Inc.)Error monitoring. Technical error reports; request bodies, cookies and personal data are not sent.Germany (EU data region); US company
Brevo (Sendinblue SAS)Transactional email (password resets, notifications) from [email protected]. No document content is sent by email.France (EU hosting)
StripePayments and billing. Subscription and billing details only; no document data.United States / Ireland

Material changes to this list will be communicated by email and updated here before any new sub-processor begins handling customer data.

Transfers to providers based in the United States or with a US parent rely on the EU-US Data Privacy Framework where the provider is certified, and otherwise on the European Commission's Standard Contractual Clauses. Cloudflare carries only the marketing website. Brevo, Stripe, reCAPTCHA and Sentry receive no customer documents, extracted text or search vectors.

Standards & attestations

GDPR Article 28 Processor Agreement In place via Google Cloud CDPA, available on request
EU Standard Contractual Clauses (2021) Module 2 + Module 3 for any residual transfers
EU–US Data Privacy Framework Google LLC is DPF-certified — secondary transfer mechanism
EU AI Pact Signatory Confirmed signatory to the EU AI Pact (Pillar II voluntary pledges), European Commission — listed on the official AI Pact signatories register; core commitments plus transparency & traceability pledges (2026)
EU Code of Practice — AI-content transparency Signatory Signatory to the Commission's Code of Practice on Transparency of AI-Generated Content (Article 50 marking & labelling) — assessed adequate by the European Commission and the AI Board (Aug 2026), now the recognised pathway for Article 50 compliance; ~190 signatories across the AI ecosystem
EU Cloud Code of Conduct Evaluating Article 40 GDPR cloud code — reviewing for potential future adherence (formal assessment not yet initiated); our processing builds on the Google Cloud CDPA
CSA STAR Level 1 ✓ Listed Docent is publicly listed in the Cloud Security Alliance STAR Registry — view registry entry
NCSC Basisscan Cyberweerbaarheid ✓ 5/5 all principles Completed the Dutch NCSC (formerly Digital Trust Center) cyber-resilience self-scan — full marks on all five principles of secure digital enterprise (Jul 2026)
Gaia-X Hub Netherlands Requested European data-sovereignty initiative — participation requested via CoE-DSC (Jul 2026)
Google for Startups Cloud Program Member Accepted into the Google for Startups Cloud Program (Start tier, Jul 2026)

Items marked Under review or In progress are active applications. Updated when issued.

Security controls

AreaControl
Encryption at restAES-256, managed by Google Cloud
Encryption in transitTLS 1.3
AuthenticationHttpOnly + Secure cookies, short-lived JWTs (1 hour), server-side session revocation
Password policyMinimum 10 characters, mixed case + digit
Access controlRole-based: company admin, department lead, employee
Audit logsAll access, document, and administrative actions logged with IP + user agent
Rate limitingPer-IP limits on auth endpoints, configurable per route
Content Security PolicyStrict CSP with explicit allowlist of trusted sources
File upload validationMIME type + magic byte validation, size caps

GDPR rights & data subject requests

Customers and their end users can exercise GDPR rights (access, rectification, erasure, portability, restriction, objection) via Docent's built-in DPO dashboard or by contacting [email protected]. We respond within 30 days as required by Articles 12–22 GDPR.

For breach notification: under Article 33 GDPR, we notify affected customers without undue delay and within 72 hours of becoming aware of a personal data breach.

Documents available on request

Email [email protected] to request any of the above.

Contact

Data protection & privacy

[email protected]

Security disclosures

[email protected]

Legal & document requests

[email protected]