How Russian Companies Can Legally Transfer Personal Data to Contractors Under 152-FZ
Russian organizations frequently outsource accounting, IT support, and customer service, yet many overlook the specific requirements of 152-FZ when personal data leaves their systems. The core question is whether the contractor acts as a processor following the client’s instructions or as an independent operator pursuing its own legal obligations.
When the client defines the purpose, such as payroll calculation or CRM administration, the contractor remains a processor. In this case a formal data processing instruction must be signed, containing all elements listed in part 3 of Article 6 of 152-FZ, including the list of permitted operations, security measures, and rules for engaging sub-processors.
Conversely, laboratories, banks, and insurers usually qualify as independent operators because they maintain their own records and bear statutory duties toward the data subjects. No processing instruction is appropriate; instead the client must rely on consent or another basis under part 1 of Article 6 and must inform individuals about the transfer in advance.
Employee data triggers an additional layer of protection under Article 88 of the Labor Code. Written consent from each employee is mandatory before salary, passport, or SNILS information may be sent to an external accountant or HR outsourcer. Consent must name the recipient, the exact data categories, and the purpose; general wording is insufficient.
Organizations are advised to ask two practical questions for every contractor: who decides why the data are processed, and would the contractor still have any legal duty toward the individuals if the service contract ended? The answers determine whether a processing instruction, a transfer agreement, or both are required.
Failure to obtain proper documentation can result in fines of 100–300 thousand rubles for officials and 300–700 thousand rubles for legal entities under part 2 of Article 13.11 of the Code of Administrative Offenses. Roskomnadzor treats each monthly transfer as a new violation, so the one-year limitation period restarts with every data exchange.
Related articles
Protecting Data Centers from Kinetic and Cyber Attacks: What Regulators Worldwide Are Proposing
InfoWatch experts have updated their April report on data center resilience, highlighting how physical and cyber threats now directly threaten business continuity and national security. Regulators in the United States, European Union, and Russia are treating data centers as strategic infrastructure requiring layered defenses that combine physical hardening, geographic distribution, and strict cybersecurity controls. The United States has launched the Cyberstrategy for America 2026 emphasizing offensive operations, Zero Trust modernization, and supply-chain restrictions. The European Union is implementing ProtectEU and the Cyber Solidarity Act with real-time threat sharing and mandatory resilience standards under DORA. Russia is advancing technological sovereignty targets, new siting rules for data centers, and Presidential Decree No. 604 that enables temporary state management of inadequately protected critical facilities. The report also notes growing recognition that attacks on data centers can constitute acts of aggression under the Tallinn Manual.
US Department of Homeland Security Orders Federal Agencies to Remove DeepSeek Products
The US Department of Homeland Security issued an order on October 19 requiring federal civilian agencies to cease purchasing products from DeepSeek and to remove related technology from government systems. The directive, published the following day, targets Hangzhou DeepSeek Artificial Intelligence, its affiliates, and any third-party products or services built on DeepSeek implementations. The measure stems from the Federal Acquisition Supply Chain Security Act of 2018 and follows a recommendation by the Federal Acquisition Security Council, though no specific incidents or evidence were detailed in the notice. The restriction applies only to federal environments and does not prohibit private sector or individual use outside government systems. No removal deadline was set, and the document does not name the signing authority. The order is filed under docket DHS-2026-0628 with the CISA implementation team listed as the contact point.
AKIT Requests Temporary Permission for Russian Companies to Transfer Personal Data Abroad After Data Center Incidents
The Association of Internet Trade Companies (AKIT) has sent a formal letter to Russian Prime Minister Mikhail Mishustin proposing a temporary exemption from strict data localization rules. The measure would allow affected companies to move critical systems and Russian citizens' personal data to data centers in friendly countries when domestic infrastructure is unavailable due to accidents or damage. Members including Ozon, Wildberries, Cooper, and Yandex Market argue that services must continue operating even if Russian facilities are compromised. The proposed special regime would apply only after an officially confirmed incident, require compliance with information security standards, and end no later than March 1, 2028. After recovery, companies would be required to return to normal data processing within Russia. Expert Alexey Muntyan noted that the mechanism activates only after incidents occur and questioned whether countries should be selected based on data protection levels rather than political alignment.
Anthropic Model Reconstructs NSA Seeds for NIST Elliptic Curves in Under 30 Minutes
An internal Anthropic research model traced the origins of the five seeds used by the NSA to generate the NIST elliptic curves P-192, P-224, P-256, P-384, and P-521. The discovery resolves a 25-year-old question that arose when the curves were standardized in FIPS 186-2 for ECDSA in 2000. Researchers combined analysis of 1990s random number generators, 34 generator-output combinations, and lattice reduction techniques to identify lrand48 initialized with Unix timestamps from May 1997 to April 1998. The P-256 seed corresponds to the 1842nd candidate from a run started on 16 August 1997, and example seeds from ANSI X9.62 follow the same pattern. The work does not demonstrate any cryptographic break or backdoor in the curves and does not recommend changes to production systems. Several questions remain open, including the seed for curve B-163 and the reason certain candidate values were discarded.