Increased fines for violations in processing of personal data

Federal Law No. 589-FZ from 12.12.2023 "On Amending the Code of Administrative Offenses of the Russian Federation" has been adopted.

Starting from December 23, 2023, fines for processing personal data without the written consent of the subject of personal data or in violation of the requirements for its execution are increased.

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Preparation of a full package of documents on personal data protection, registration with Roskomnadzor

Client

Large company. Business activities:

  • Wholesale of non-specialized food, beverages and tobacco products
  • Wholesale of industrial chemicals

Objectives

Protection of personal data:

  • Development of a full package of documents on personal data from scratch
  • Registration of the company with Roskomnadzor taking into account the new requirements for cross-border transfer of personal data
  • Visit to the client and verification of proper storage of documents on personal data of both employees and counterparties. applicants
  • Checking the access system at the entrance to the back offices for compliance with 152-FZ

Work stages

  • Verification of all existing forms of personal data documents;
  • Visit to the client, verification of proper storage of personal data documents, including in case of non-automated processing of employees' personal data;
  • Negotiations with the client and choice of strategy in interaction with counterparties - individuals, sole proprietors for compliance with the norms of 152-FZ in terms of obtaining consents for processing of personal data;
  • Checking the pass system and internal regulations reflecting the system of issuing passes for the company's employees;
  • Development of a full package of documents taking into account the new forms of consent according to the latest amendments to the 152-FZ;
  • Registration of the company with Roskomnadzor as an operator for processing personal data, taking into account the specifics of cross-border transfer of personal data.

Changes regarding personal data from March 1, 2023: new document forms, requirements of Roskomnadzor, and necessary actions for personal data operators

Until March 1, 2023, employers are required to submit special notifications to Roskomnadzor (hereinafter referred to as RKN) regarding the processing of personal data.
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