Russia: Implemented Federal Law No. 242-FZ including localisation requirements

On 1 September 2015, Federal Law No. 242-FZ on Amending Certain Legislative Acts Concerning Updating the Procedure for Personal Data Processing in Information-Telecommunication Networks, including data localisation requirements, was implemented. The Federal Law No. 526-FZ, from 31 December 2014, changed the implementation date from 1 September 2016 to 1 September 2015. The Law introduces the obligation for companies that collect and process the personal data of Russian users to store the data within Russia and provide media regulator Roskomnadzor with the location of data storage facilities. The Law applies to foreign companies if they collect and process Russian user data. Exemptions from the data localisation requirement include cases where the processing is necessary for achieving the purposes stipulated in an international agreement or a Federal Law or is necessary to fulfil obligations imposed on operators by the Law, enforcement and judicial purposes, providing public services by state or municipal authorities, professional activities of a journalist or mass media, scientific, literary or other creative activity, only if it does not violate a data rights and freedoms.