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Filing a notification regarding the initiation of personal data processing starting 1 September 2022

Mr. Erich Rath

The Sterngoff Audit team informs that starting 01 September 2022, changes to Federal Law No. 152-FZ “On Personal Data” take effect to tighten the requirements for the processing of personal data. In particular, a notification must be submitted to Roskomnadzor on the initiation of personal data processing.

This change applies primarily to all employers.

The fine for failure to submit a notification about the initiation of personal data processing to Roskomnadzor amounts to RUB 5,000 and RUB 500 for officials.

Moreover, the change gives rise to a risk of claims from employees (both current and dismissed).

In view of the foregoing, the auditors recommend that Roskomnadzor be notified of the initiation of personal data processing. Please note that the notification of the initiation of personal data processing can be submitted to Roskomnadzor in paper or electronic form, and there is no charge for filing a notification.

In addition, when submitting information, for each purpose of processing personal data an operator is required to indicate the categories of personal data, the categories of subjects whose personal data are processed, the legal basis for the processing of personal data, the list of actions involving personal data, and the methods of processing personal data.

For more information on how to submit this notification, please follow the link (Personal Data Portal – Notification Form (

The Legal Department of Sterngoff Audit LLC provides services for the development of local regulatory documents on this issue and helps clients submit a correct notification to Roskomnadzor.