The Roskomnadzor notification form is not a questionnaire about a company but an extract from documents that must already exist. Regulators expect operators to copy information already recorded in the personal data processing policy, the list of processed data categories, the appointment order for the responsible person, the act determining the protection level of information systems, and the list of applied security measures.
Before opening the form, operators must verify whether notification is required at all. Following the September 2022 amendments to 152-FZ, only three narrow exemptions remain: data in state information systems created for national security, processing performed exclusively without automation tools, and processing required by transport security legislation. Paper-based card indexes qualify for the second exemption, but Excel files, 1C, CRM systems, email, and cloud storage constitute automated processing.
Five documents supply the answers required by the form. The personal data processing policy provides processing purposes. The attached list of data categories supplies both categories of data and categories of data subjects. The appointment order gives the name and contact details of the responsible person. The protection level act and threat model, prepared under Government Decree No. 1119 of 1 November 2012, feed the largest text block. The list of applied security measures populates the two fields on protective measures and tools.
The form itself contains several practical features. A draft can be saved at any time and later retrieved via a permanent link. Entering an INN triggers an automatic check against the register; if a record already exists, the system blocks submission of a primary notification and offers links to the change-of-information form. An auto-population link can import data from a previously submitted notification using its identifier and email address.
Section I asks for the region of registration, taken from the Unified State Register of Legal Entities, and separately for the regions where processing actually occurs. The latter field refers to territories where staff with data access work or where equipment storing personal data is located, not merely the legal address or client locations.
Subsequent sections require operators to list each processing purpose together with five mandatory details: categories of data subjects, categories of data, legal grounds, actions performed, and data retention periods. Protection measures must be described with reference to the protection level act. Geographic scope, cross-border transfers, and final declarations complete the form.
After submission, the operator remains obliged to keep internal documents up to date and to notify Roskomnadzor of any changes. Failure to submit or submission of inaccurate information can result in administrative liability, although the absence of a record alone does not automatically trigger a fine without detection during an inspection.
