How Russia's Article 10.1 on Personal Data Dissemination Emerged: Legislative History and Reform Flaws
The Russian personal data protection regime underwent significant change with the introduction of Article 10.1 in Federal Law No. 152-FZ. The reform, formally enacted through Federal Law No. 519-FZ, took effect on 1 March 2021 and required separate consent for processing personal data that a subject permits to be disseminated.
Author Anton Gorelk in, First Deputy Chairman of the State Duma Committee on Information Policy, Information Technology and Communications, sponsored the original bill 1057337-7 on 17 November 2020. The explanatory note claimed that once data appeared on websites, operators could freely accumulate, supplement and analyse it for purposes such as targeted advertising, without further control by the data subject.
This framing overlooked existing judicial practice. In case No. A40-5250/2017, courts upheld Roskomnadzor positions that data from open profiles on VKontakte, Odnoklassniki, Twitter and Avito did not automatically become publicly available personal data under Article 8. The Supreme Court refused to review the case. A further Tagansky District Court ruling on 3 March 2020 ordered an internet page that provided unrestricted access to personal data without consent to be included in the register of violators under Article 15.5 of the Law on Information.
The initial draft proposed a detailed consent mechanism: subjects would list specific categories of data, name the exact internet resources where data could appear, and set conditions or prohibitions. Two distinct prohibitions were envisaged—one preventing the operator from transferring data to an unlimited circle of persons (except providing access), and another preventing that circle from further processing (except receiving access). The draft also allowed subjects to demand cessation of processing at any time without proving a violation.
During the first reading on 9 December 2020, the responsible committee itself stated that the bill’s declared objectives were not achieved by its provisions. The Legal Department warned that the bill’s use of the term “access” conflicted with the definition already contained in 152-FZ, where processing includes transfer and transfer includes access. The committee nevertheless recommended passage, promising corrections before the second reading.
The final text preserved the broad definitions of processing, transfer and dissemination while adding new exceptions and a lengthy new category of data alongside the existing Article 8. The resulting framework mixes several legal models without adequate reconciliation, rendering consistent practical application extremely difficult for operators.
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