Russian Data Privacy – Court Practice Update

The end of 2017 was marked with a few interesting court decisions, which may be useful for businesses to know for the assessment of their future dealings in Russia. Some of the decisions confirmed our earlier understanding of the relevant legal provisions or the earlier verbal clarifications of the regulator:

Photos on ID documents are considered biometric personal dataⁱ

Companies should take a closer look at the data they are processing and take this decision into account. Potentially the companies may want to delete or destroy any documents with photos from ID documents as, otherwise, such processing requires the implementation of additional compliance measures.

Consents need to be specific. Too general language should be avoided