Just over a year ago, on December 31, 2014, Russian President Vladimir Putin signed into law new personal data localization requirements, mandating that data operators collecting personal data about Russian citizens “record, systematize, accumulate, store, amend, update and retrieve” data using databases physically located in Russia. Among other things, passage of the new law generated immediate concerns regarding its scope, implementation, and implications. On August 3, 2015, less than a month before the new law was to take effect, the Russian Ministry of Communications and Mass Media published official “guidelines”, largely in the form of FAQs, in an attempt to “clarify” the law and address some of the questions and concerns it generated. http://www.minsvyaz.ru/ru/personaldata/ (in Russian). Nevertheless, one question that has remained unanswered since the law has gone into effect (September 1, 2015) is whether the law introduces trade restrictions that violate World Trade Organization regulations. Russia has been a WTO member since August 2012. Continue reading “Russia’s data localization law – a violation of WTO regulations?”