Cross-border transfer of personal data in Russia: possible ban or restriction and relations between Russia and the Council of Europe regarding Convention 108

Cross-border transfer of personal data in Russia: possible ban or restriction and relations between Russia and the Council of Europe regarding Convention 108

27 February 2023

Dear Ladies and Gentlemen,

As a part of a reform of Russian data protection laws, Roskomnadzor adopted new rules for ban or restriction of cross-border transfer of personal data outside of Russia. Roskomnadzor may decide to ban or restrict cross-border transfer of personal data in the following cases:

  • After the consideration of a data controller’s notification on cross-border transfer of personal data;
  • Upon the motion of a competent authority to Roskomnadzor.
Read more information here
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Note: please be aware that all information provided in this letter is based on an analysis of publicly available information as well as our understanding and interpretation of legislation and law enforcement practices. Neither ALRUD Law Firm nor the authors of this letter bear any liability for the consequences of any decisions made in reliance upon this information.

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ALRUD Law Firm

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Т: +7 495 234 96 92, Т: +7 495 926 16 48, info@alrud.com
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