Comparative Characteristics of the GDPR and Russian Legislation on Personal Data

Abstract

This article examines the main reasons for the development and implementation of the General Data Protection Regulation (GDPR) of the European Union, which replaced the EU Data Protection Directive 95/46 adopted in 1995. In this article authors defined the relevance of the application of these regulations in the Russian practice. The methodology of the work is based on a comparative analysis of the GDPR and the Federal Law No. 152 “On personal data”, due to which conclusions about the general features and differences of the main provisions were made. The scientific novelty of the study is determined by the authors' proposals aimed at improving the legislation regulating the problems of protection and processing of personal data. The possibility of applying the provisions of the GDPR is considered on specific examples, which made it possible to identify certain criteria that show that the organization’s activities are carried out in the scope of the GDPR. In conclusion, five stages of introducing the principles of GDPR into the organization’s activities are proposed for the most efficient work with data and compliance with legislation. Also, some controversial decisions related to the processing of personal data in Russian and foreign practice were considered on the example of such organizations as VKontakte, Facebook, Google, ICANN and EPAG.