
How Russian Companies Can Legally Transfer Personal Data to Contractors Under 152-FZ
The article explains the legal distinction between data processors and independent operators when outsourcing tasks involving personal data. It details that the role of a contractor is determined by who sets the processing purpose, not by the service contract itself. For processors, a detailed data processing instruction under Article 6 of 152-FZ is required, while independent operators need a separate legal basis such as consent or contract performance. Special rules apply to employee data under Article 88 of the Labor Code, mandating written employee consent for transfers to third parties. The guidance also covers sub-processing risks, transparency obligations, and penalties under Article 13.11 of the Code of Administrative Offenses. Practical checklists help organizations classify contractors and prepare the correct documentation.
HabrSep 4, 2026Translated from Russian

