From September 1, 2015 the new Federal Law ФЗ-242 “On amendments to a number of legislative acts of the Russian Federation in connection with clarifying personal data processing procedures for information and telecommunication networks” comes into effect. The Ministry of Communications and Mass Media of the RF has made clear on its web site that Russian and foreign airlines, as well as ticket reservation and issuing agencies, do not fall within the scope of this new law

1. ACCOUNTOR ACCOUNTOR Moscow Stockholm
Sadovnicheskaya nab. 79 Shpalernaya ul. 54 St. Petersburg Oslo
115035 Moscow, Russia 191015 St. Petersburg, Russia Kyiv Copenhagen
+7 495 788 00 05 +7 812 325 82 94 Helsinki Utrecht
moscow@accountor.ru spb@accountor.ru
accountor.ru accountor.ru
From September 1, 2015 the new Federal Law ФЗ-242 “On amendments to a number of
legislative acts of the Russian Federation in connection with clarifying personal data
processing procedures for information and telecommunication networks” comes into effect.
The Ministry of Communications and Mass Media of the RF has made clear on its web site
that Russian and foreign airlines, as well as ticket reservation and issuing agencies, do not
fall within the scope of this new law:
According to the provisions of Part 2 and 3 of Article 105 of the Russian Federation Air
Code, contracts for the carriage of a passenger, cargo or mail by air are considered
confirmed by an air ticket and baggage ticket, an airway bill, or a postal waybill accordingly;
the air ticket, baggage ticket and other documents used for providing the air transportation
of passengers can be issued electronically (electronic traffic document), granted that
provisions of the air transportation contracts are distributed through the automatic
information system used for ticketing. Consequently, in order to comply with the law,
airlines have to process the personal data of passengers used for issuing documents that
confirm the contract’s execution.
According to Article 85.1 of the Russian Federation Air Code, for the purposes of aviation
security airlines must ensure passengers’ personal data transfer into automatic centralized
personal data databases in compliance with RF laws on transportation security and on
personal data protection; international air carriers are also required to transfer such data to
the authorized bodies of foreign states in compliance with RF international agreements or
laws of the foreign states from which the air carrier departs, arrives at or passes through in
transit, to the extent set by RF laws, unless otherwise stipulated by RF international
agreements. It should be noted, that the Russian Federation is a party to a number of
international air carrier conventions, namely the Chicago Convention (“Convention on
International Civil Aviation”), Warsaw Convention (“Convention for the Unification of Certain
Rules Relating to International Carriage by Air”), Guadalajara Convention (“Convention
Supplementary to the Warsaw Convention for the Unification of Certain Rules Relating to
International Carriage by Air Performed by a Person other than the Contracting Carrier”),
that also form an integral part of the legal regulation of air carriers’ operations and the
corresponding information processes.
Airlines and Ticket Reservation
Companies Do Not Fall Under the
New Personal Data Regulations

2. Based on the above, the provisions of Part 5, Article 18 of the Federal Law “On Personal
Data” do not cover Russian and foreign air carriers’ operations connected with the gathering
and processing of personal data of citizens of the Russian Federation, which is used for
making reservations, or issuing and granting tickets, baggage tickets and other documents,
because they fall within the exception contained in Clause 2, Part 1, Article 6 of the Federal
Law “On Personal Data”
Also the provisions of Part 5, Article 18 of the Federal Law “On Personal Data” do not cover
operations of persons acting on behalf of an air carrier (authorized agents), covered by
Clause 6 of the Common rules for air service of passengers, baggage, cargo and
maintenance requirement of passengers, exporter and receiver, approved by the Ministry of
Transportation Order №82 of June 28, 2007 “Approval of Federal Aviation Rules ‘Common
rules for air service of passengers, baggage, cargo and maintenance requirement of
passengers, exporter and receiver’”, as well as operations of other persons connected with
the processing of personal data of citizens of the Russian Federation, which is used for
making reservations, or issuing and granting tickets, baggage tickets and other documents,
including in an electronic form, if such operations are covered by RF law or a corresponding
international agreement, including for the purposes of ensuring aviation security.
Accountor offers to analyse your company’s personal data storage regulation and ensure it
complies with the new law.
For professional advice on the matter, please contact us:
Samuli Pesu
Deputy CEO
Mobile: +7 926 710 43 61 /
+358 50 553 20 34
Office: +7 495 788 00 05
Email: Samuli.Pesu@accountor.ru
Pertti Sarosalo
Sales Director Nordics
Mobile: +358 40 590 7603
E-mail: Pertti.Sarosalo@accountor.ru
Daniil Berlizov
Senior Business Development
Manager
Mobile: +7 916 539 68 66
Office:+7 495 788 00 05
Email: Daniil.Berlizov@accountor.ru
ACCOUNTOR ACCOUNTOR Moscow Stockholm
Sadovnicheskaya nab. 79 Shpalernaya ul. 54 St. Petersburg Oslo
115035 Moscow, Russia 191015 St. Petersburg, Russia Kyiv Copenhagen
+7 495 788 00 05 +7 812 325 82 94 Helsinki Utrecht
moscow@accountor.ru spb@accountor.ru
accountor.ru accountor.ru