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Tag Archives: Roskomnadzor

Posted in Data Protection & Privacy Natalia GulyaevaMaria SedykhBret Cohen

Russian Data Protection Authority Publishes Privacy Policy Guidance

On 31 July, the Russian data protection authority, Roskomnadzor, issued guidance for data operators on the drafting of privacy policies to comply with Russian data protection law. Russia’s 2006 privacy law – Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (Personal Data Law) – requires, among other things, that Russian data operators must adopt a privacy policy … Continue Reading

Posted in Data Protection & Privacy Natalia GulyaevaMaria SedykhBret Cohen

Russia Increases Fines for Violations of Data Protection Laws

On 7 February 2017, the Russian President signed into law a bill (link in Russian) introducing amendments to the Russian Code on Administrative Offences that increases the amount of the fines imposed for violating Russian data protection laws and differentiates the relevant offences’ types. The greatest increase raises maximum fines for certain violations from RUB 10,000 to 75,000 (approx. USD … Continue Reading

Posted in Data Protection & Privacy Natalia GulyaevaMaria SedykhBret Cohen

Russia Releases 2017 Data Privacy Inspection Plans; Microsoft Passes 2016 Inspection

At the end of 2016, territorial divisions of the Russian Data Protection Authority, Roskomnadzor, published their 2017 plans for conducting inspections of local companies’ compliance with Russian data privacy requirements, including data localization. The inspection plans contain a number of prominent multi-national and Russian companies.

For instance, the inspection plan of Roskomnadzor’s territorial division for the Russian Central Region includes … Continue Reading

Posted in Data Protection & Privacy Natalia GulyaevaMaria SedykhBret Cohen

Moscow Court Upholds Ruling to Block LinkedIn in Russia for Non-Compliance with Data Localization Law

In a case with major significance for foreign online businesses that do business in Russia, on Thursday, 10 November the Moscow City Court sustained a lower court ruling that granted the request of the Russian Data Protection Authority (Roskomnadzor) to block access to social network LinkedIn within Russian territory.

As we described in an earlier post, Roskomnadzor brought the … Continue Reading

Posted in Data Protection & Privacy Natalia GulyaevaMaria SedykhBret Cohen

Russia Data Localization Update: Results from Regulatory Inspections Clarify Enforcement Approach

We last reported on Russia’s data localization law earlier this year when the Russian data protection authority, Roskomnadzor, released its inspection plan for 2016. Since then, Roskomnadzor has been conducting compliance inspections both according to the plan and in individual cases when it has reason to do so. The results of those inspections and recent comments by the Head … Continue Reading

Posted in Data Protection & Privacy Natalia GulyaevaBret Cohen

Russia Releases Data Localization Inspection Plan for 2016

In mid-January, the territorial divisions of Russia’s Data Protection Authority, Roskomnadzor, uploaded their 2016 plans for conducting inspections of local companies’ compliance with Russia’s data localization requirements, and there are a number of prominent multi-national companies on the list.

For instance, the inspection plan of Roskomnadzor’s territorial division for the Russian Central Region (in Russian) contains a number of organizations … Continue Reading

Posted in Data Protection & Privacy Natalia GulyaevaMaria SedykhBret Cohen

Russian Data Localization: Two Months In

We are now almost two months into the era of Russia’s Data Localization Law, which came into force on 1 September.  While some expected immediate enforcement, the Russian Data protection Authority, Roskomnadzor, has not yet taken any action for a violation of data localization requirements.  Last month, Roskomnadzor did take formal enforcement action to block a website and add Continue Reading

Posted in Data Protection & Privacy Natalia GulyaevaMaria SedykhBret Cohen

Russian Data Localization Law: First Day in Force and Schedule for Compliance Inspections

Today, on 1 September, the Russian Data Localization Law came into force. So far there have been no unexpected developments or reports of any unplanned inspections by Roskomnadzor, the Russian Data Protection Authority.  Existing planning documents, however, provide some predictability for organizations subject to the law about the schedule under which Roskomnadzor plans on conducting compliance inspections.

Roskomnadzor’s plan for … Continue Reading

Posted in Data Protection & Privacy Natalia GulyaevaMaria SedykhBret Cohen

Russia Update: Regulator Publishes Data Localization Clarifications

The Russian Ministry of Communications, the agency that oversees the Russian data protection authority which will be enforcing Russia’s Data Localization Law, published unofficial clarifications on its website that provide a view into how the Ministry believes organizations must comply with the law. While these clarifications are non-binding, they constitute the only written regulatory guidance that has been published to … Continue Reading

Posted in Data Protection & Privacy Natalia GulyaevaBret CohenMaria Sedykh

Russian Regulator Publishes Data Localization Clarifications One Month Before Sept. 1 Effective Date, Plus Other Developments

In September 2015 the Russian Data Localization Law will come into force, requiring organizations that collect personal data from individuals located in Russia to store that data within Russian territory. In this blog post, we summarize recent developments on how the law will be applied, including the unexpected publication of regulatory guidance issued by the government this week.

After many … Continue Reading

Posted in Data Protection & Privacy, Policy & Regulation

Recording and Deck from Webinar: Update on New Russia Data Localization Law

Thank you to everyone who participated in the Hogan Lovells webinar “Russia Data Localization Update: New Details Emerge from Meetings with Russian Regulator” on 2 April 2015. This update follows an October 2014 presentation that outlined Russia’s newly enacted Data Localization Law. In this webinar, Hogan Lovells privacy and data protection attorneys Natalia Gulyaeva and Bret Cohen provided insight into … Continue Reading

Posted in Data Protection & Privacy, Policy & Regulation Natalia GulyaevaMaria SedykhBret Cohen

Russia Data Localization Law Update and Webinar: New Details Emerge from Meetings with Russian Regulator

With the September 2015 effective date of Russia’s Data Localization Law less than six months away, the Russian data protection authority, Roskomnadzor, has still not issued any formal guidance on how it interprets the law’s broad requirement that companies must process and store the personal data of Russian citizens within Russia. Roskomnadzor has, however, recently held a series of meetings … Continue Reading