One decision governs everything. Content — prompts, retrieved documents, model responses — never leaves the client’s perimeter. Only aggregated metadata reaches Firedog. The analysis that needs to read content runs in place, inside the client’s VPC; only the resulting figures are sent. We bring the compute to the data, not the data to the compute.
Roles under GDPR
Client (the fund)
Controller. Holds the content and decides the purposes of processing.
Firedog
Processor, on usage metadata only.
LLM providers
The client’s processors — content reaches them from the client, never via Firedog.
The data, in two categories
| Category 1 — Metadata | Category 2 — Content | |
|---|---|---|
| Examples | Model, tokens (input / output / cache), cost, latency, timestamp, request id, trace context, decomposition counters (retrieved vs. used tokens, static-prefix size), the attribution map (key/service → team/component), and the collaborator identifier | Prompt text, retrieved documents (RAG), model responses |
| Leaves the perimeter? | Yes — aggregated, to Firedog | No — never |
| Sensitivity | Low to moderate | High (the fund’s business data) |
| Where it lives | Firedog control plane (EU) | The client’s VPC only |
Where the personal data actually is
- Content is confidential business data, not personal data — and it does not leave the client.
- Personal data, in the GDPR sense, is limited to the collaborator identifier attached to their usage. The data subjects are the client’s own staff.
- Recommendation: pseudonymise that identifier at the collector — Firedog emits it as a salted hash, never the raw identity — which further shrinks the GDPR surface. See Sensitivity profiles.
Purposes
Attribute AI cost by team and component
Turn one opaque provider invoice into spend filed to the desk and workflow that caused it.
Detect waste and recommend optimisations
Surface the re-read tax and cheaper-model opportunities, measured — not guessed.
No individual profiling. No HR or performance-evaluation purpose.
The flows
A — Client apps to collector (in the VPC)
Metadata plus local access to content. Transient, inside the client’s network.
B — Collector to Firedog platform
Aggregated metadata only. Stored: raw for 30–90 days, aggregates in long retention.
C — Content to local analysis to counters
Content is read in place; only the counters leave. Content is not stored by Firedog.
Retention
| Data | Retention |
|---|---|
| Raw metadata | 30–90 days |
| Aggregates | Long retention [Placeholder — to fix, e.g. 24–36 months] |
| Content | Not retained by Firedog — held in the client’s VPC on the client’s own schedule |
| Access / deletion logs | [Placeholder — to fix, e.g. 12 months] |
Deletion
Deletion is triggered by end of contract, a GDPR request, or retention expiry. It is propagated to subprocessors (hosting, backups), with a deletion log kept as proof.Data residency
Hosting is EU only. The Firedog platform — the metadata store and the web app — runs on Railway in region EU West (Amsterdam, Netherlands), i.e. GCPeurope-west4. This is aligned with a finance client base.
Transfer nuance. The underlying infrastructure is Google Cloud, whose parent is US-based. Even in an EU region, the transfer mechanism is covered by Railway’s DPA and Google’s Data Privacy Framework certification and standard contractual clauses.
Subprocessors
The processing chain is Firedog → Railway (hosting) → Google Cloud (infrastructure). Railway hosts the Firedog platform — the control plane: the ingest API, the metadata database, and the web app. In the in-VPC model, client content does not reside on Railway; it stays in the client’s VPC.| Subprocessor | Service | Location | Compliance |
|---|---|---|---|
| Railway | Platform hosting + metadata database | EU West — Amsterdam (NL) | SOC 2 Type II + SOC 3; GDPR DPA |
| Google Cloud (via Railway) | Underlying infrastructure | europe-west4 (NL) | SOC 2 / ISO 27001; DPF-certified + SCC |
| [Observability / logs] | Technical monitoring | [Placeholder — to specify] | [Placeholder — to verify] |
Completeness
Coverage is not asserted — it is measured. Firedog reconciles the metadata it received against the provider’s own invoice, so any gap between the two is surfaced rather than hidden. The reconciled difference is shown, not assumed away.Internal access
[Placeholder — to formalise: who at Firedog can see which data — role-based access control, least privilege, per-client isolation, and access logging.]
What this enables
An Article 30 record, a DPIA where required (likely a light one, given content never leaves the client), a client DPA, a privacy policy, and a 72-hour breach-notification procedure.Security & data residency
The split-plane threat model, and the CallRecord vs. CallMetadata boundary in detail.