Data localization and cross-border transfers: mapping the route

For Russian citizens' data, assess requirements governing collection and the use of databases located in Russia for recording, organization, storage, updating, and retrieval.

Trace each user field's first POST from browser through load balancer, application, queue, and primary database. Mark temporary buffers, serverless logs, and error tracking separately because they may receive content before the main database. Configuration should demonstrate where initial operations occur rather than merely showing the hosting provider's billing country.

Include CDN, monitoring, support, payments, messaging, cloud storage, and contractors. Record countries and data categories for each.

For each recipient record the provider entity, processing role, storage and access countries, data categories, subprocessors, retention, and deletion method. Verify configuration rather than marketing language because CDN, analytics, or helpdesk services may use multiple regions. If a service cannot fit the approved design, reduce transferred data or choose an alternative before launch.

Before a cross-border transfer begins, the controller submits a separate notice of intent to Roskomnadzor and performs the assessment of the foreign recipient required by law. Before launch, verify the current form, required information, possible regulator decisions, and contractual safeguards. Document the decision.

Enable a cross-border route only after the separate prior notice to Roskomnadzor and documented review of the applicable procedure, recipient conditions, and contractual safeguards. Account for any regulator response or prohibition and do not rely on an old checklist or a provider's previous approval. A region change, new subprocessor, or expanded data set should trigger another control gate before production activation.

Backup geography and remote administrative access belong on the map. Encryption does not remove the need to establish a transfer basis.

Inventory snapshots, object storage, disaster copies, administrator downloads, and contractor VPN access. For each define encryption, key jurisdiction, restore roles, and verifiable deletion. Recovery tests should run in a controlled environment and must not reintroduce previously deleted records into production. Temporary foreign access should also be recorded as a data route.