Data Protection – To Russia With Love
Data Protection – To Russia With Love
Data Protection Russia
Russia’s new data protection law came into effect on the 1st of September 2015. It’s now required by law to store personal details of Russian citizens on servers physically located in Russia. Copies of the personal details may be stored outside of Russia.
The law was not scheduled to enter into legal force till 1st of September 2016, however the Russian President Vladimir Putin moved to push the effective date to 2015.
Personal data is any information allowing the person to be identified. So a name by itself is not personal data but a name together with an IP address or physical address or credit card number etc. becomes personal data. The law includes an exception for Airlines given their heavy reliance on international GDSs (Global Distribution Systems).
Apple has become one of the first large non-Russian international companies to comply with the law. Facebook, Google, Twitter and other some other large international companies have been given an extension to comply until 1 January 2016.
As a commercial merchant selling goods and services to Russian consumers the most likely point in your sales process where you would come across personal data is at the payment stage. Compliance to the law can then be achieved by working with a payment service provider who is storing personal details in Russia.
If you’re a merchant performing KYC (e.g. gambling, forex, binary options etc) then the easiest avenue would be to outsource KYC of Russian consumers to an external party who again is storing personal details in Russia.
Be aware that if you are non compliant with the law then your business / site could be shut down / banned by the Russian authorities at any moment.
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