Russia's Law On Personal Data In Practice

When it was first announced, Russia's new requirement for the personal data of its citizens to be housed in-country raised many questions and doubts. However companies that didn't act may now be feeling the effect.

The amendments to Federal Law no. 152-FZ "On Personal Data" (hereinafter – the Law) came into effect on September 1, 2015. They obliged personal data operators (hereinafter – Operators) to process the personal data of Russian citizens using servers located in Russia.

Since they were first passed the new requirements have raised a lot of questions from both operators and ordinary citizens - primarily due to the vague wording of the Law, the absence of the court practice, and even partially contradictory clarifications from the regulatory authorities.