152-FZ and business email: what counts as personal data

Outreach & lawUpdated 2 min read

Russian personal data law (Federal Law 152-FZ) applies to information about an identifiable individual. For outreach, the key question is which addresses identify a person.

Generic vs named addresses

  • info@, sales@, zakaz@ - not personal data; they belong to the company (case А40-139096/2022).
  • ivan.petrov@company.ru with his name and position - personal data.
Practical rule

Prefer department addresses the company published for contact. They are lawful to use as addresses and usually reach the right team.

Direct marketing (Art. 15)

Using personal data for promoting goods and services by direct contact requires prior consent. Whether this covers employees reached at work in B2B is disputed; the cautious reading is that it does.

Operator duties

  • Publish a privacy policy.
  • Notify Roskomnadzor before processing.
  • Since 1 Jul 2025, record and store Russian citizens' data in databases located in Russia.
  • Since 1 Sep 2025, collect consent as a separate document, not buried in terms.

Fines

Under the Code of Administrative Offences as amended on 30 May 2025: processing without legal basis - RUB 150,000-300,000 for companies; without required consent - RUB 300,000-700,000; failure to notify Roskomnadzor - RUB 100,000-300,000.

FAQ

Is a director's name from the state register personal data?

Yes. It is public, but publicity does not remove 152-FZ obligations for further processing.

This article is for information only and is not legal advice. Laws change - check the current wording (consultant.ru, garant.ru) before launching a campaign and consult a lawyer in disputed cases.

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