Why Tracium runs
on your servers.
Ship documentation is often controlled data.
An AI that reads it has to stay where the data
is allowed to be.
- Author
- Ben Kebdani
- Published
- Updated
- Reading time
- 5 minutes

In short
- Maintenance and repair documentation for naval vessels is often controlled technical data. ITAR names it explicitly, and the EU Common Military List covers the technology to operate and repair warships.
- A cloud AI has to read your manuals in clear text on its provider’s servers. ITAR’s exemption for encrypted cloud storage does not cover that.
- Tracium runs on your own infrastructure. Models, manuals and data modules stay inside your network, with no cloud and no third-party AI.
- Your security team reviews one system inside your walls instead of a chain of outside services.
Why is ship documentation controlled data?
For a naval vessel, the technical documentation describes how the ship’s systems are built, run and repaired. Much of it counts as controlled technology under export rules, and many programmes add security classifications on top.
US export rules say so outright. Under ITAR, technical data is information required for the design, production, operation, repair, testing, maintenance or modification of defence articles, including instructions and documentation. A maintenance manual for a defence article fits that description almost word for word.
In Europe, national export controls follow the Common Military List of the European Union. Category ML9 covers vessels of war and special naval equipment. Category ML22 covers the technology required to develop, produce, operate, install, maintain, repair and overhaul the items on the list. The maintenance procedures of a frigate are that kind of technology. Which rules navies set for the documentation itself is in S1000D in naval shipbuilding.
What happens when a cloud AI reads your manuals?
A general AI service runs on its provider’s servers. To draft from a manual, the model has to read it. The text leaves your network and is decrypted and processed on hardware you do not control, often with logs kept for a while. A promise not to train on your data does not change where the data went.
This is not a theoretical risk. In May 2023 Samsung banned generative AI tools for its staff after employees had uploaded sensitive source code to ChatGPT, as CNBC reported.
ITAR does have a rule for the cloud. Sending or storing unclassified technical data is not an export if it stays end-to-end encrypted and no third party is given the means to decrypt it (22 CFR 120.54). A language model cannot work on encrypted text. A provider that drafts from your manuals holds them in clear text, so that rule cannot cover the drafting.
Whether a given use needs a licence is for your export control officer to decide. The point is that the question arises the moment the manuals leave your network.
Is a private or sovereign cloud enough?
A cloud region in your own country, or a provider that promises not to look, changes the provider, not the principle. For controlled data, three questions decide: who operates the hardware, who can get hold of the keys, and which law the operator answers to.
The third one is easy to miss. Under US law, a provider based in the US has to disclose data in its possession on a lawful request “regardless of whether such communication, record, or other information is located within or outside of the United States” (18 U.S.C. 2713, added by the CLOUD Act in 2018). A data centre in Europe does not change that. On your own servers, the answer to all three questions is you.
What does on-premise mean in Tracium?
Tracium runs on your own infrastructure. The language models, the supplier manuals, the drafts and the finished data modules stay on your servers. Tracium does not call a cloud service or a third-party AI.
Your IT decides where the data sits and who has access to it. Access inside Tracium is role-based, so writers, reviewers and approvers each see what their role allows. Your security team reviews one system inside your network, not a chain of outside services and the companies they in turn rely on.
The same rules for the AI as for the writers
Your writers work on approved systems inside the yard. An AI that drafts for them should work under the same rules. That is why Tracium comes to the documents, not the other way round.
What to ask any AI documentation vendor
Whoever you talk to, these five questions show quickly where your data would go:
- Where do the models run, and who operates the hardware?
- Does any text, prompt or log leave our network, for support or monitoring as well?
- Which other companies can see our data?
- Does the system work without a connection to the internet?
- Who holds the keys, and who can decrypt what?
Questions and answers
Can we use a public cloud AI for ITAR technical data?
Only with great care, and usually not without your export control officer. ITAR treats documentation for defence articles as technical data. Its exemption for the cloud covers data that stays end-to-end encrypted with no third party able to decrypt it, and a language model has to read the text. This is not legal advice: the decision belongs to your export control function.
Is naval documentation in Europe export controlled too?
Often. EU member states control military items and technology according to the Common Military List of the European Union. Category ML9 covers vessels of war and ML22 the technology needed to operate, maintain and repair listed items. Dual-use items fall under Regulation (EU) 2021/821.
Does any data leave our network with Tracium?
No. Tracium runs inside your network. The models, the supplier manuals, the drafts and the data modules stay on your servers, and Tracium does not call a cloud service or a third-party AI.
What is the difference between on-premise and a private cloud?
On-premise means the software runs on hardware you own or control, inside your network. A private cloud is a dedicated environment that may still be operated by someone else. For controlled data, what matters is who operates the hardware and who could read the data.
Sources
- 22 CFR 120.33, Technical data, eCFR
- 22 CFR 120.54, Activities that are not exports, reexports, retransfers, or temporary imports, eCFR
- Common Military List of the European Union, Council of the European Union, approved 24 February 2025
- Regulation (EU) 2021/821 setting up a Union regime for the control of exports of dual-use items
- 18 U.S.C. 2713, Required preservation and disclosure of communications and records, Legal Information Institute
- Samsung bans use of AI like ChatGPT for staff after misuse of chatbot, CNBC, 2 May 2023
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