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Tag Archives: Data Localization

Posted in Data Protection & Privacy Natalia GulyaevaMaria SedykhBret Cohen

Russia Partially Releases 2018 Data Privacy Inspection Plans

Two weeks ago, certain territorial divisions of the Russian Data Protection Authority, Roskomnadzor, published their 2018 plans for conducting inspections of local companies’ compliance with Russian data privacy requirements, including with Russia’s data localization requirement. The inspection plans contain a number of prominent multi-national and Russian companies.

Within such inspections, Roskomnadzor assesses the compliance of the entity with Russian … Continue Reading

Posted in Data Protection & Privacy Mark Parsons

China’s Data Localization Measures Open for Comment

On 11 April 2017 the Cyberspace Administration of China published a circular calling for comments on its draft Security Assessment for Personal Information and Important Data Transmitted Outside of the People’s Republic of China Measures (the Draft Export Review Measures). Public comments are open through 11 May 2017.

The main legislative purpose of the Draft Export Review Measures is to … 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 Policy & Regulation, Technology Jun WeiSherry GongNolan ShawAndrew McGintyMark Parsons

China’s second draft of the Cyber Security Law continues to propose more stringent regulation of cyberspace

On 6 July 2016, a second draft of the People’s Republic of China Cyber Security Law was released to the public for comment following its second reading by the Standing Committee of the National People’s Congress.  The deadline for submitting comments on the second draft is 4 August 2016.

Given the growing cyber threat globally, the Chinese move towards more … 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

Hogan Lovells Partner Highlights Compliance Goals with Russia’s Data Localization Law

On 1 September 2015, Russia’s much anticipated data localization law came into force.  In recent interviews with European CEO and The Financial Times, Natalia Gulyaeva, partner in Hogan Lovells’ Moscow office, highlighted some key elements for multinationals to consider when doing business in Russia.  In the interviews, Natalia explains that Roskomnadzor is not likely to conduct compliance … 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