July 2014: Russian Federal Law No. 242-FZ (the “Law”) amended existing Russian data privacy laws to require that personal data of Russian citizens be processed by servers within Russian borders.
Sept 1, 2015: The Draft Law comes into force. It does not provide for a transitional period.
“In order to check whether the data operators are storing the personal data in Russia the Russian DPA (Roskomnadzor) will be conducting field audits to check whether the companies have server capacity in Russia and checking the content of the server.” Anna Shasina (Bird&Bird).
And don’t think you can just have a ‘mirror server’ in Russian territory to satisfy the law; it looks as though all processing must be done on the Russian servers.
Guess it’s time to start investing in ‘HOSTKEY’ and other Russian data centers!
For a heads-up on the new law, head over to Hogan Lovells page where you can find a webinar and slide deck.
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