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However, this interpretation may not offer much of a reprieve, as that interpretation only applies if no changes are further applied to the data.

From September 2015 onward, any processing of personal data of Russian citizens (namely, the recording, systematization, accumulation, storage, update, change, or retrieval of personal data) should be done in accordance with the new data localization requirement, even if collected and stored abroad before the effective date.

On the other hand, foreign businesses with less of a physical connection to Russia, or without a website specifically targeted to Russian users, appear to be less likely enforcement targets under the Ministry’s guidance.

That said, Russian courts have the final say on the scope of the law’s jurisdiction, so while the Ministry’s guidance is helpful in determining likely enforcement targets, it does not definitively exempt any organizations from the localization requirements until the law is tested in the courts.

Collection of personal data The Data Localization Law states that “when collecting personal data,” a data operator must process the personal data of Russian citizens within Russia.

The law therefore connects the localization obligation with the of personal data, a prerequisite for the law to apply.

The guidance also clarifies that the law applies to all “data operators” notwithstanding whether they collect personal data online or offline.

However, the guidance states that any changes to the personal data collected and localized in Russia should first be made in the primary database located in Russia and the transferred abroad to the secondary database, if needed.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.If, however, an organization only incidentally receives personal data (e.g., through email), or does not purposefully collect personal data from third parties (e.g., when a data operator only receives personal data from another legal entity for routine business activities), the Data Localization Law will not apply.Cross-border transfer The guidance makes clear that the Data Localization Law does not prohibit the transfer of personal data outside of Russia.It therefore is possible to first enter and process personal data collected from Russian citizens in a database located in Russia (“primary database”), and then to transfer that data to databases located abroad and administered by other persons (“secondary database”), so long as the transfer complies with Russian cross-border transfer requirements.

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