Wednesday, September 9, 2015
Russian Data Localization Law Comes into Effect
Any wishful thinking that the effective date of the new Russian data localization law would be postponed were dashed when the government allowed the law came into force on September 1, 2015. While the applicability of the law to HR data remains murky, the Russian DPA, Roskomnadzor, has indicated verbally that it does not intend to begin enforcing the law until January 2016. In addition, fines for non-compliance are currently quite low, with an upper limit of RUB 25,000 (under $500), although this could change. More telling is the authority of Roskomnadzor to name-and-shame offending companies, order a cessation of data processing and confiscate data processing equipment. Companies that already have their primary HR database for Russian employees located in Russia, with transfers abroad limited to relevant processing that otherwise meets Russian data protection requirements, should be able to weather the uncertainty surrounding the new law.