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ARTICLE · 19 FEBRUARY 2021

Comparing Privacy Laws: GDPR V. Russian Law On Personal Data

The General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR') and the Federal Law of 27 July 2006 No. 152-FZ on Personal Data

RussiaPrivacy

Introduction

The General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR') and the Federal Law of 27 July 2006 No. 152-FZ on Personal Data ('the Law on Personal Data') both aim to guarantee protection for individuals' personal data and apply to organisations that collect, use, or share such data.

In particular, both laws share similar provisions, for example, in relation to legal basis for processing. Under both the GDPR and the Law on Personal Data, data processing shall only be lawful if the data subject has given consent to processing, where processing is necessary for the performance of a contract, as well as for compliance with a legal obligation, among other things. In addition, the GDPR and the Law on Personal Data both outline fairly consistent cross-border data transfers obligations, providing that such transfers only take place to countries ensuring an adequate level of protection. Moreover, both laws are fairly consistent in relation to the

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