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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.Retrospective character of the law The law applies only to data processing activities that take place after its effective date.Therefore, the guidance states that personal data collected and stored abroad before 1 September 2015 does need to be stored in Russia.Cross-border transfer The guidance makes clear that the Data Localization Law does not prohibit the transfer of personal data outside of Russia.It therefore is possible to first enter and process personal data collected from Russian citizens in a database located in Russia (“primary database”), and then to transfer that data to databases located abroad and administered by other persons (“secondary database”), so long as the transfer complies with Russian cross-border transfer requirements.

The guidance is purposefully vague on this point, which indicates that the regulator likely is still considering its final position on the issue.According to the guidance, this is because the law exempts the processing of personal data for the purpose of pursuing objectives envisaged by an international treaty of the Russian Federation, and commercial air travel is governed by such international treaties.The Ministry named a number of such international treaties, including the Chicago Convention of 7 December 1944, the Warsaw Convention of 12 October 1929, and the Guadalajara Convention of 18 September 1961.Applicability of the law Under standard Russian jurisdictional rules, laws apply only within the territory of Russia.The clarifications, therefore, state that as a general rule the Data Localization Law should not apply to non-residents of Russia, including foreign businesses.

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