Information Technology & Communications
Implementation Deadline to Store and Process Personal Data of Russian Citizens on Russian Territory Is 1 September 2015
On 21 July 2014 Russia adopted a law which generally requires all companies that collect and process personal data of Russian citizens to use databases located in Russia (the “Law”).1
On 31 December 2014 Russia adopted a new implementation deadline for the above requirements, 1 September 2015 (which is one year earlier than initially provided by the Law).2
Russian and foreign companies that collect the personal data of Russian citizens (either through websites or otherwise) will be required to maintain databases to store and process such personal data on Russian territory.
If companies fail to comply, the Russian regulatory authorities will be able to block access to non-compliant websites based on a relevant court decision and/or to impose administrative fines and issue binding orders to cease violations.
To date, Russian authorities have not adopted any subordinate legislation or official interpretations which would clarify the minimum steps required to comply with the Law. However, such clarification is anticipated in the near future.
This LEGAL ALERT is issued to inform Baker & McKenzie clients and other interested parties of legal developments that may affect or otherwise be of interest to them. The comments above do not constitute legal or other advice and should not be regarded as a substitute for specific advice in individual cases.
1. Federal Law No. 242-FZ dated 21 July 2014 “On Introducing Amendments to Certain Legislative Acts of the Russian Federation with regard to Personal Data Processing in Information and Telecommunications Networks.”
2. Federal Law No. 526-FZ dated 31 December 2014 “On Introducing Amendments to Article 4 of the Federal Law “On Introducing Amendments to Certain Legislative Acts of the Russian Federation with regard to Personal Data Processing in Information and Telecommunications Networks.”
For further information please contact
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Arseny Seidov +7 495 787 27 37
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