Marketing and Communications Director of Raketa LLC Daria

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Moreover, the emergence of such a GIS, according to the participants of the ABD, directly contradicts the instructions of the president and the goals of the national project "Digital Economy" and the "Data Economy" that is replacing it. Thus, the ABD believes that draft law No. 992331-7 does not change the definition of anonymized personal data (data as a result of anonymization under the draft law remains personal), but an exception is made for cases of transfer to the GIS, this means a de facto rejection of the institute of consent to the processing of personal data and other principles of processing uae whatsapp resource personal data, which is a direct contradiction to the requirements of paragraph 2 b of Instruction No. Pr-113 of January 28, 2024. The document also directly prohibits the extraction of data compositions from the FGIS, and the creation of data processing tools and the construction of models in the interests of business), which contradicts the National Strategy for the Development of Artificial Intelligence until 2030. Also, according to the ABD, such gaps as the lack of a procedure for anonymizing personal data and obtaining consent to the processing and anonymization of personal data contradict paragraph 1.3 of the Federal Project "Regulatory Framework of the Digital Environment" of the National Program "Digital Economy of the Russian Federation".

Zubritskaya believes that this bill could significantly complicate the work with data for companies: "First of all, the entry into force of the new regulations will increase the costs of companies to ensure data security at the transfer nodes. In addition, the concerns of companies regarding the strong centralization of data and its security sound convincing, since by hacking the centralized GIS in which the data is stored, intruders will be able to gain access to too much information. And this contradicts the best practices for ensuring data security. A potential source of problems is also the fact that the set and depth of data for transfer may vary, which means that companies will not be able to set up a unified transfer process. It will be necessary to either involve development each time, or create a separate complex system, thereby incurring additional costs to support this process."

Sergey Nazarenko, head of the big data department at Reksoft Group, believes that the bill could complicate the work of companies processing personal data, especially those using personal data for multiple purposes, which must now be clearly indicated in the consent to data processing. At the same time, according to his assessment, problematic requirements will appear later, when Roskomnadzor establishes additional requirements for the depersonalization of personal data.

Vyacheslav Borisov, the leader of the software testing product cluster at Sfera Platforms, also sees serious gaps that could potentially become complex and costly for personal data operators: "The bill does not yet contain detailed requirements for the technical base and the list of solutions for transferring data to a single system. This is a fairly critical aspect that needs to be worked out, since it imposes additional costs on businesses for implementing IT tools."