Hl dating ru
Applicability of the law Under standard Russian jurisdictional rules, laws apply only within the territory of Russia.
The clarifications, therefore, state that as a general rule the Data Localization Law should not apply to non-residents of Russia, including foreign businesses.
There is a notable exception, however, when an organization uses “computing powers” (i.e., automatic processing) to purposefully collect personal data from third parties, in which case the organization is required to comply with the data localization requirements.The guidance is vague on this question, merely stating that each company must assess on its own whether its handling of employee personal data is subject to this exemption, the correctness of which will be further evaluated in the course of regulatory inspections.This position gives a little more leeway than the previous (but unofficial) position of Roskomnadzor—the Russian data protection authority which will be conducting the inspections, and which is subject to the authority of the Ministry of Communications—which previously said that the processing of employee data be subject to the Data Localization Law.Retrospective character of the law The law applies only to data processing activities that take place after its effective date.Therefore, the guidance states that personal data collected and stored abroad before 1 September 2015 does need to be stored in Russia.
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The bottom line under the guidance is that when an organization purposefully collects personal information directly from Russian citizens, or uses a third party to do so on its behalf, or purposefully collects personal data of individuals from third parties beyond routine business activities, that collection is subject to the Data Localization Law.