Russia Data Localization Update: Results from Regulatory Inspections Clarify Enforcement Approach

While it is clear that the regulators still expect Russian personal data to be stored in Russia, companies may have more of a grace period to cure instances of noncompliance than originally expected, so long as they are making a good faith effort to comply. That said, the relatively low rate of violations may reflect the fact that most of the companies inspected to date are those located within Russia, and not the U.S.-based and other multi-national companies whose network infrastructure is not already located in Russia, requiring greater effort and expense to comply. Roskomnadzor* has indicated its plan to broaden the scope of its audits to cover these types of companies starting in 2017.

*The Russian Federal Executive body for Supervision in the Sphere of Telecom, Information Technologies and Mass Communications

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