On 1 September 2015, Russia’s much anticipated data localization law came into force. In recent interviews with European CEO and The Financial Times, Natalia Gulyaeva, partner in Hogan Lovells’ Moscow office, highlighted some key elements for multinationals to consider when doing business in Russia. In the interviews, Natalia explains that Roskomnadzor is not likely to conduct compliance audits on large multinational companies for some time and will allow for the transfer of data out of Russia as long as the primary database is inside Russia. She also highlights that because Russia’s definition of “personal data” is very broad, a prudent course of action is for companies to treat all information used to assist in the identification of individuals as “personal data.”
To watch Natalia’s video interview with European CEO, click here.
To read The Financial Times report on the new law, click here.