Russian law on personal data
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Roskomnadzor generally considers it important for data operators to adopt a relatively detailed data processing policy so that data subjects are russian law on personal data of all potential actions to be taken with their personal data, such as the purposes for processing and recipients of their personal data. Roskomnadzor expects companies to proactively control the processing of their personal data to comply with the data processing notice. Specifically, a data operator’s policy should explain that the data operator enters into contracts with third party recipients to protect the personal data.
Since its 1 July 2017 implementation, there is a separate administrative liability for non-compliance with the obligations to publish the privacy policy and to provide unrestricted access to such policy. Although the guidance is non-binding and of a recommendatory nature, it is likely that Roskomnadzor, when conducting compliance investigations, will consider whether data operators are following the guidance. Therefore, data operators should strongly take these recommendations into account when developing privacy policies to comply with the Personal Data Law. Hogan Lovells International LLP and Hogan Lovells US LLP, each of which is a separate legal entity. Prior results do not guarantee a similar outcome. 2019, Hogan Lovells US LLP and Hogan Lovells International LLP. A controversial new law on personal data storage that comes into force in Russia on 1 September is set to create problems and confusion for a huge number of companies.
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By submitting my Email address I confirm that I have read and accepted the Terms of Use and Declaration of Consent. Federal Law 526-FZ was adopted last year on grounds of “overall state security issues” and “increased instances of personal data leakage”, but these justifications have been criticised by some entrepreneurs. The law stipulates that all personal information provided by Russian citizens when registering on websites, making online purchases or sending electronic messages is considered personal data and must be stored inside Russia. Companies violating the terms of the new law will be placed on a blacklist by Roskomnadzor, Russia’s communications watchdog, which would lead to access to their websites being blocked, as well as fines. The new law will affect the vast majority of businesses operating in Russia. 6 million companies process personal data in the country. The legislation has already discouraged some foreign companies from entering the Russian market.
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