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The bottom line under the guidance is that when an organization purposefully collects personal information directly from Russian citizens, or uses a third party to do so on its behalf, or purposefully collects personal data of individuals from third parties beyond routine business activities, that collection is subject to the Data Localization Law.
If, however, an organization only incidentally receives personal data (e.g., through email), or does not purposefully collect personal data from third parties (e.g., when a data operator only receives personal data from another legal entity for routine business activities), the Data Localization Law will not apply.
Employee-related data Similar to the international treaty exemption, the Data Localization Law provides an exemption for personal data processed for the purpose of pursuing objectives envisaged by Russian law.
The contours of this exemption are unclear, and many have asked the Ministry of Communications to clarify whether it exempts organizations from applying the localization requirements to the personal data of their employees, the processing of which is subject to certain legal requirements.
The guidance also clarifies that the law applies to all “data operators” notwithstanding whether they collect personal data online or offline.
However, the guidance states that any changes to the personal data collected and localized in Russia should first be made in the primary database located in Russia and the transferred abroad to the secondary database, if needed.
That said, there is still no official statement expressly exempting any particular processing of employee data from the localization requirement.