Travel data can reveal more about a company than is immediately apparent. Why the storage location isn’t the only factor when it comes to business-critical data, and why digital data sovereignty is becoming relevant for business travel management.
It starts with a hotel booking. Two nights in Frankfurt, a meeting in Munich, followed by three days in Vienna. Taken individually, these are just pieces of travel information. But taken together, they can form patterns.
Analyzing a company’s travel data over an extended period can potentially reveal insights into business activities, relevant markets, or the travel patterns of specific groups of people. This also includes personal booking, contact, and payment information.
Travel data is therefore more than just the basis for booking and billing. It is part of company data and should be protected and controlled as such.
The server is located in Europe. The law isn’t necessarily in place.
Where data is stored and processed is an important question. But not the only one.
Equally important are who operates the underlying infrastructure, the legal jurisdiction to which a provider is subject, and who can access the data and under what conditions. Therefore, a server location within the European Union does not automatically mean that only European legal frameworks are relevant.
This is demonstrated by the discussion surrounding extraterritorial legislation. The US CLOUD Act, for example, can, under certain legal conditions, permit companies subject to US law to disclose data, even if the data is located outside the US.
In June 2025, this very question was discussed at a hearing before the French Senate, using the example of an international cloud provider. The debate makes one thing particularly clear: physical storage location, operator structure, and legal jurisdiction must be considered together when evaluating an infrastructure.
This does not mean that companies have to decide for or against a particular market or supplier. It’s about understanding and consciously evaluating their own dependencies.
Data sovereignty goes beyond data protection.
Data protection and data sovereignty are closely related, but they do not mean the same thing.
Data protection regulates the conditions under which personal data may be processed and how it must be protected. Data sovereignty goes further, asking: How transparent and traceable are data processing, access rights, and technological dependencies within a business-critical process?
Specifically, this means: Where is data processed? Who can access it? What legal frameworks apply to the providers involved? And what external technologies and infrastructures does a business-critical process depend on?
European regulations also address some of these issues. The EU Data Act, for example, specifies requirements for data processing services. NIS2 increases the cybersecurity and risk management requirements for companies within its respective scope. International data transfers, in turn, are subject to their own separate legal frameworks.
Ultimately, what matters is not so much a single regulation, but a company’s ability to understand its data flows and technological dependencies.
Why this is particularly relevant in business travel management
Hotel processes no longer end with the booking confirmation.
Booking information can be linked to payment and billing processes, reporting, travel and expense systems, and other business processes. This simplifies workflows and ensures data consistency. At the same time, the importance of the underlying data and infrastructure architecture increases.
Travel management and procurement departments are therefore no longer just asking about the content and conditions offered by a booking platform. The processing of the resulting data is also becoming a selection criterion.
Data protection and compliance look at the legal framework and access options. IT considers interfaces, information security, and technological dependencies. And management wants to know how controllable a business-critical process will remain in the long term.
Data sovereignty thus becomes a common theme for several business units.
Three questions companies should ask
A sovereign data strategy doesn’t begin with a specific product or certificate. It begins with transparency.
Where is our data processed? Physical location remains a crucial criterion. Companies should know in which countries and legal jurisdictions business-critical data is processed.
Who can access the data? Besides the location, it is important which companies and individuals can have administrative access to systems and data and what legal framework they are subject to.
What technological dependencies exist? Business-critical processes can depend on platforms, cloud infrastructures, interfaces, and other technology providers. The more transparent these dependencies are, the better the associated risks and the resilience of business-critical processes can be assessed.
These questions don’t belong solely to IT. They also affect procurement, data protection, compliance, and corporate governance.
How ehotel implements data sovereignty
ehotel’s technology architecture relies on an independent European infrastructure. The servers are located in Berlin, and therefore exclusively in Germany. The data center operators used are subject to European law.
This clearly answers the key questions of data sovereignty: The data is processed in Germany. Administrative access to production systems is not granted to personnel outside Europe. System-critical dependencies on non-European cloud infrastructures are avoided.
This isn’t just about individual hotel bookings. Booking, payment, billing, and reporting can all be part of a seamless hotel process. The more closely these processes are interconnected, the more important a transparent data and infrastructure architecture becomes.
This creates transparency for travel management. Data protection, compliance, and IT can assess key issues regarding data storage, access, and technological dependencies in a comprehensible manner. And for management, data sovereignty becomes a concrete component of technological risk management.
The crucial question
Data sovereignty doesn’t begin with the privacy policy. It begins with the question of where business-critical data is processed, who can access it, and what legal and technological dependencies the underlying infrastructure is subject to.
Choosing a booking platform is therefore not solely a matter of hotel offerings, functionality, and price. It also involves data protection, compliance, IT, procurement, and corporate risk management.
Whose data is this, exactly? The answer should be clear for every company: It’s your data. And it should stay that way.