Workday and Roskomnadzor

On 4 July 2020, BDO Unicon Outsourcing held an online meeting: Workday and Roskomnadzor. How not to Violate the Federal Law On Personal Data when Working with the System. In the course of the event, the experts discussed how to prepare for an inspection by the Federal Service for Supervision of Communications, Information Technology, and Mass Media (Roskomnadzor) and to minimize possible violations. The meeting was moderated by Inna Perelet, PEPS Project Manager, FM Logistic. More than 140 participants joined the webcast.

While implementing the Workday system, Russian companies have to take into account local legislation regulating the collection and transfer of the personal data to the system. According to Federal Law No. ФЗ-152, the initial collection and storage of the personal data must be carried out on the territory of the Russian Federation, while Workday servers are located outside the country. Thus, to comply with the legal requirements, companies are forced to maintain two databases or arrange for the data integration from the local to the international system, as well as to decide which Workday modules they are ready to use.

During the event, Evgeny Soloviev, a consultant of Tech Group (a member of Clifford Chance), explained what kind of information falls into the personal data category, how Roskomnadzor regulates the collection and cross-border transfer of such data to the international system, and what liability a company may face for violating the requirements for localization.

Tatyana Novikova, Head of Digital Solutions at Hilti Russia, shared the experience of the transition to Workday, talked about the risks that an organisation may face, and the steps that were taken to determine the final scenario for the project implementation.

The event ended with a discussion, during which the participants received answers to their questions related to the application of ФЗ-152 in the course of Workday modules implementation.