Russia: Right to be Forgotten law in force from 1 January

Russia’s “Right to be Forgotten Law”, signed by President Putin on 13 July 2015, will enter into force on 1 January 2016. The Law imposes an obligation on search engines that disseminate advertisements targeted at consumers located in Russia to remove search results listing information on individuals where such information is unlawfully disseminated, untrustworthy, outdated, or irrelevant, law firm Hogan Lovells reports.

Search engines are defined as information systems that perform web searches and provide information on third parties’ websites, i.e. search engines such as Google. The Law does not provide any clarification concerning the criteria for determining whether an advertisement is targeted at Russian consumers. Hogan Lovells’ lawyers, Natalia Gulyaeva and Maria Sedykh, predict that the following criteria will be taken into account:
1. websites registered using a Russian top level domain (.SU, .RU, .RF); and
2. websites and advertisements that are in the Russian language (including where the website has another non-Russian top level domain).