Prohibitions on cross-border transfer of medical data

Capital Legal Services lawyers have prepared a plan for the proper transfer of data abroad.

We remind you that on March 1, 2023, amendments to the Federal Law "On Personal Data" regarding the cross-border transfer of personal data came into force. Now, any company transferring personal data abroad is required to notify Roskomnadzor in advance. In certain cases, Roskomnadzor may even prohibit such transfers altogether.

The first bans on the cross-border transfer of personal data have been announced. According to Roskomnadzor, seven Russian operators received refusals, including:

• financial companies;
• logistics companies.

Roskomnadzor representatives cited the discrepancy between the purposes of the cross-border transfer and the purposes specified during their collection, as well as their volume and content, as the reason for banning cross-border transfers.

Therefore, due to incorrectly completed notifications, Roskomnadzor may limit or completely prohibit the cross-border transfer of personal data.

Lawyers from Capital Legal Services discussed the new procedure for cross-border transfers at a Business Breakfast held on 16 May at the company's St. Petersburg office and online. Following the Business Breakfast and in light of recent events, we remind you how to properly transfer personal data abroad.