Decision to Block LinkedIn in Russia Demonstrates Russian Government’s Commitment to Enforce New “Localization” Requirements for Processing Personal Data

November 21, 2016

The recent ruling against LinkedIn Corporation (“LinkedIn”) by the Moscow city appellate court, allowing the government to block LinkedIn’s internet services in the Russian Federation (“RF”), may be seen as a signal that the Russian Government intends to use its new powers of enforcement under its data protection laws to block companies who fail to come into compliance with the new rules. The decision has garnered a great deal of media attention and outcry. Even Russia’s largest bank Sberbank has publicly commented on potential difficulties with recruitment that the blocking of LinkedIn will impose on it.

The court decision is based on both the new legal requirements concerning the handling of personal data under the recent Federal law No. 242-FZ, as well as on Russian law provisions that have been in existence for some time now regarding the necessity to obtain proper consents from individuals in order to collect and process their personal data. In short, LinkedIn was charged with violating Russian law by processing Russian citizens’ personal data on databases not located in Russia and by allegedly failing to obtain the required consents for such operations. In this update, we focus on the former issue (failure to localize), which is a relative novelty of Russian law.

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