Last Friday, Russia blocked LinkedIn based on a Russian court’s finding that LinkedIn violated Russian “localization” law that requires companies holding personal data of Russian citizens to store it on servers located within Russian borders. This law came as an amendment to Russian data privacy laws, “Regarding information, information technologies and the protection of information,” “Regarding telecommunications,” and the Codex of Administrative Violations. The amendments, which came into law in September 2015, required websites and telecommunications providers to begin storing “on the territory of the Russian Federation information regarding the receipt, transfer, sending and/or processing of voice information, written text, images, sounds or other electronic messages of the users of Internet,” within six months after the law went into effect.
Russia took the position that the new requirements were necessary to ensure personal data on Russian consumers is properly protected, something the Russian government said can only be done if the servers are within Russian jurisdiction. The penalty for violating the law by companies was established at 500,000 roubles (approximately $8,000). The law also contemplated a punishment much worse than the monetary penalty. Specifically, the amendment empowered Roskomnadzor, the Russian federal agency charged with overseeing telecommunications services and information technologies, to investigate violations of the new law and to petition courts to block websites who refuse to comply.
Following the adoption of this law, many companies that collect and process Russian citizens’ information began working toward achieving compliance by ensuring that this data stayed on Russian soil. Some, however, decried the law as forcing businesses to needlessly invest in servers in Russia and rework established data workflows.
Soon after the law went into effect, Roskomnadzor began exercising its investigative powers and taking suspected violators to court. To keep track of the adjudicated violators, Roskomnadzor created a special registry of websites marked for blocking in case of continued noncompliance following the adjudication. LinkedIn, which has over 6 million registered Russian users, made Roskomnadzor’s “black list” registry and, on Friday, November 18, became the first website to be blocked in Russia for the violations of the localization law.