What happened?
On 12 July 2022, the European Data Protection Board (the
“EDPB”) published a Statement 02/2022
on personal data transfers to the Russian Federation. As a
consequence of the war initiated by the Russian Federation against
Ukraine, Russia has been excluded from the Council of Europe and is
therefore no longer a contracting party to its respective
conventions and protocols. Russia will also cease to be a
contracting party to the European Convention on Human Rights as of
16 September 2022. According to the EDPB, these changes will have a
significant impact on the level of protection of data subjects with
respect to the transfers of personal data from the European
Economic Area (the “EEA”) to
Russia.