Personal data information systems to be aligned with the law no later than 1 January 2011


Legal Update No. 106

Our Legal Update No. 87 of 19 November 2009 noted that personal data information systems would have to be brought in line with the law.

Goltsblat BLP advises that Federal Law of 27 December 2009 No. 363-FZ “On Amendments to Articles 19 and 25 of the Federal law “On Personal Data”” came into effect on 29 December 2009.

The new Federal Law has deferred for 1 year – until 1 January 2011 inclusively – the deadline for bringing personal data information systems into line with the requirements of the Federal Law “On Personal Data” and associated acts.

These requirements include confirmation of compliance (particularly certification) by personal data systems and licensing of relevant activities (including the need to obtain a licence from the Federal Service for Technology and Export Control to engage in activities involving technical protection of confidential information).

In addition, the new Law excludes use of encryption (cryptographic) means of data protection from the list of the personal data operator’s duties. Consequently, operators will be able to use such means at their own discretion and will do so only if it is impossible to ensure security of personal data unless encryption (cryptographic) means are employed.

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