Russia’s Right to Be Forgotten Law Effective January 2016

Vladimir Putin recently authorized a “right to be forgotten” law that goes into effect January 1, 2016. The law (Federal Law No. 264-FZ) sets forth a procedure of communications between operators of search engines and those who wish certain data be removed. It requires operators of search engines to remove links to personal information if the information is inaccurate, if it was unlawfully released, or if it is deemed to be irrelevant or outdated. If the operator fails to remove the data or provide a suitable reason for refusal to do so, the person requesting deletion may file a civil claim in Russian court.

While Russian Parliament is separately considering a bill on administrative fines for operators who fail to comply, it has not voted on it yet. Until the bill is adopted by the Russian Parliament and signed by the President, Russian state bodies will not have the authority to levy fines for those who fail to comply.

TIP: With Russia joining the EU in enacting a “right to be forgotten” law, search engine operators operating in both the EU and Russia may want to work with their government affairs partners to help shape the contours of these laws.