Russian Data Localization Law

All personal data of Russian citizens must be recorded, systematized, accumulated, stored, clarified (updated), and extracted using databases physically located within Russian territory, with no exceptions for backup or processing purposes.

Data centers must ensure that the primary copy of personal data resides on servers within Russia's geographic and jurisdictional boundaries, and any replication or backup systems must not constitute the primary storage location outside Russia.

This requirement applies from the moment personal data is collected, meaning initial ingestion, loading, and operational storage cannot occur on foreign infrastructure.

Organizations are prohibited from transferring personal data of Russian citizens to foreign countries as a standard practice, with extremely limited exceptions requiring explicit legal authorization or reciprocal data protection agreements.

Any temporary transfer for processing, analysis, or disaster recovery must comply with strict conditions including written contracts, government approval, and documented security measures.

Data centers must implement technical controls to prevent automated or unintended cross-border data movement, including network segmentation and firewall rules explicitly blocking unauthorized international data flows.

Organizations operating databases with Russian personal data must notify Roskomnadzor (Federal Service for Supervision of Communications, Information Technology and Mass Media) and the FSB regarding their data processing activities, database locations, and infrastructure details.

Data centers must maintain current documentation of all databases containing Russian citizen data, including physical server locations, system architecture diagrams, and data flows.

These notifications must be updated within specific timeframes when database locations, operators, or processing methods change, with failure to notify triggering administrative penalties.

Data center facilities must be owned, leased, or controlled by Russian entities with documented legal rights to house personal data processing systems within their infrastructure.

Foreign-owned or operated data centers cannot serve as primary storage locations for Russian personal data, creating a requirement for Russian subsidiary ownership or long-term contractual control.

Data centers must provide evidence of physical location within Russia through legal documentation, property deeds or leases, utility registrations, and address verification with Russian authorities.

Data centers must implement technical controls to isolate Russian personal data from foreign networks, including dedicated servers, separate network segments, and encryption for all inter-facility communications.

Backup systems, disaster recovery sites, and redundant infrastructure must all remain within Russian territory, eliminating reliance on international cloud providers for failover capabilities.

Network traffic analysis and monitoring systems must specifically identify and prevent any outbound data flows containing personal information, with logging and audit trails maintained for compliance verification.

Data center operators must maintain comprehensive documentation demonstrating their understanding of personal data processing operations, database contents, access controls, and compliance measures.

Written policies, data processing agreements, and operational procedures must explicitly address Federal Law No.

242-FZ requirements, with trained personnel responsible for monitoring and enforcing localization compliance.

Data centers must provide audit trails documenting all access to databases containing Russian personal data, with particular attention to foreign individuals or entities attempting data access.

Data centers must establish logging systems that create permanent, tamper-proof records of all database access, data modifications, backup operations, and attempted transfers of personal data.

Audit logs must capture user identity, timestamp, action performed, data accessed, and result of each operation, with retention periods of at least one year and availability for Roskomnadzor inspection.

Regular internal audits must verify that no personal data has been transferred outside Russian territory and that all processing occurs on Russian-located infrastructure.

Data centers must design and implement disaster recovery, backup, and business continuity strategies using exclusively Russian-based infrastructure, eliminating reliance on international cloud providers or foreign data centers for recovery operations.

Recovery time objectives (RTOs) and recovery point objectives (RPOs) must be achievable using domestic resources only, requiring investment in multiple Russian data center facilities or partnerships.

Data centers must document and demonstrate recovery procedures that maintain continuous Russian residence of personal data throughout all scenarios including facility failures, network disruptions, and emergency situations.