In the first part of the insight-series ‘Bridging Islands, Connecting Futures’, we discussed the importance of interconnectivity within the Caribbean – and briefly addressed the topic of data sovereignty. This insight further sheds light on the latter’s importance. Data sovereignty entails that data is subject to the laws and governance structures of the country or region where it is collected, processed, or stored. This means that data generated within a particular jurisdiction should remain subject to its laws and regulations, regardless of where it physically resides or is transferred to. When a company or government based in the Caribbean stores its data in a data center located in the U.S. (which is often the case), that data is subject to U.S. jurisdiction due to the CLOUD ACT. The latter can raise concerns about privacy, control and compliance.
The important underlying link between data sovereignty and subsea cable systems
When discussing data sovereignty in the Caribbean, it’s important to have a good understanding of the history of subsea cable systems, which are crucial for access to the internet. Subsea cabling in the Caribbean dates back to the 19th century, connecting the region with Europe and the Americas. One of the first key routes was established in 1871, linking Jamaica to Cuba and then onward to the Bahamas and the United States with telegraph lines. These early systems, part of a broader British imperial communication network, allowed for faster international information exchange, placing control firmly in the hands of foreign powers. Mid-20th century, the region transitioned from telegraph lines to telephone cables and eventually to fiber-optic cables – which are part of critical infrastructure for internet connectivity – in the late 20th and early 21st century. The fiber-optic cable system ARCOS-1 (Americas Region Caribbean Ring System), launched in 2001, connects over 24 landing points across 15 countries and has become a backbone of regional internet traffic over time.
While this historic reliance on foreign-owned or foreign-managed cable systems has dramatically improved regional connectivity, it has also led to reduced data sovereignty for Caribbean nations. Much of the region’s digital traffic routes through data centers and internet exchanges located in the United States or Europe to this day, often subjecting Caribbean data to the jurisdiction and surveillance frameworks of those countries.
The use of foreign cloud induces risk
Like most other organizations in the world, Caribbean governments and businesses heavily rely on the largest global cloud providers, such as Amazon Web Services, Google Cloud and Microsoft Azure for data storage and processing. While these services offer great benefits, such as scalability and accessibility, they also subject Caribbean data to the purview of foreign laws, notably the U.S. CLOUD Act. This legislation allows United States law enforcement agencies to access data stored by U.S.-based companies, even when the data resides outside U.S. borders, thereby negatively impacting data sovereignty for data owners.
Harmonizing the Caribbean’s data regulation environment
Each country has its own laws and regulations governing data protection, privacy and security. These laws define how data can be collected, processed, stored and transferred within that jurisdiction – forming the basis of data sovereignty. While some Caribbean nations, such as Jamaica and Barbados, have enacted data protection legislation, there is currently no unified regional framework scoping data protection. The lack of alignment herein weakens the region’s ability to uphold data sovereignty, makes it difficult to coordinate responses to cross-border data security threats, and complicates compliance for businesses operating in multiple Caribbean markets.
An example of a legal framework for the Caribbean to go by when addressing the lack of regional alignment is the EU’s General Data Protection Regulation (GDPR). The GDPR establishes a harmonized legal framework across EU member states, requiring organizations to follow key principles, such as ensuring robust security measures to protect personal data from unauthorized access, disclosure or destruction. It also includes provisions that restrict the transfer of personal data outside the EU to countries or entities that do not offer an adequate level of protection. A similar framework in the Caribbean would strengthen data sovereignty, streamline compliance and enhance public trust in digital services across the region.
Promoting regional collaboration and federated cloud solutions
The combination of a historically foreign-controlled subsea cable network, heavy reliance on international cloud providers and fragmented regional regulations is further compounded by the lack of local infrastructure for data storage and management. There are Caribbean nations do not yet have the resources to independently build and maintain a secure, resilient digital infrastructure, leaving them inevitably dependent on external providers. This dependency not only increases vulnerability to service disruptions but also undermines data sovereignty – as sensitive information often resides in and is governed by foreign jurisdictions.
To strengthen the Caribbean’s collective digital position and reduce dependence on foreign cloud services, the region could explore the development of a Caribbean federated cloud. This approach would require coordinated, harmonized strategies and policies from local governments to ensure that cloud services operate under a unified framework – one that upholds true data sovereignty across the region. To achieve this, Caribbean nations must unite to define shared principles for managing critical cloud-related issues such as data storage, access control, cybersecurity and cross-border data flows. By collaborating, not only will individual countries enhance control over national data; the entire region will substantially increase negotiating power – enabling superior deals with stakeholders in telecommunications, hardware, software and other key areas of IT infrastructure. A federated cloud would be a strategically significant step toward regional self-reliance, digital resilience and long-term economic competitiveness.