Important Changes to Russian Data Protection Rules

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There has been an important development in Russian Data Protection Law.

On July 22, 2014 a new law amending the law on data protection and law on information was signed off by the Russian President and thus was officially adopted. The law, will come into force on September 1, 2016.

The law requires all personal data operators to store and process any personal data of Russian individuals within databases located in Russia (subject to few exceptions). The penalty for violation of this requirement is ultimately the blocking of websites involving unlawful handling of Russian personal data. A Register of Infringers of Rights of Personal Data Subjects shall be established by the Russian telecommunication authority (Roskomnadzor) and from there, Roskomnadzor may move to block websites.

As the law is newly passed and not in effect yet, it is unclear as to how this register and the website blocking would work in practice, but we note that blocking websites is a commonly used enforcement method in Russia.

Please see full alert below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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