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March 29 2016

Russia Releases Data Localization Inspection Plan

In mid-January, the territorial divisions of Russia's Data Protection Authority, Roskomnadzor, uploaded their 2016 plans for conducting inspections of local companies' compliance with Russia's data localization requirements, and there are a number of prominent multi-national companies on the list.
 
This policy of extending the inspections to entities having online activities is in line with the position Roskomnadzor expressed at its November 2015 Personal Data Conference, where Roskomnadzor's representative informed attendees that in 2016 the regulator would focus its enforcement efforts on organizations acting via Internet.
 
At the same conference, a Roskomnadzor representative announced that its inspections as of that date resulted in three administrative fines issued under the data localization requirement.
 
Companies operating in Russia should check these inspection lists to determine whether they, or members of their industry, will be subject to audits in the upcoming year.