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

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.