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FZ-152 and a website owned by an individual: what to indicate in the Processing Policy?
Hey!
I noticed that for most sites that belong to legal entities, in the Personal Data Processing Policy, it is logical that either the name of the company or the full name of the individual entrepreneur is indicated as one of the parties. How to be the owner of a personal website - an individual? By law, an individual is an operator of personal data. So, you need to indicate the full name of the individual, apparently.
1. Is it correct to indicate "Site Administration" as a party?
2. Has anyone heard about precedents of fines from Roskomnadzor for site owners?
2.1. What is the procedure for issuing a fine: Rkn looks at the owner of the domain and sends a notification through the registrar?
Addendum to the question:
Gentlemen, who signs the processing policy in their personal Web projects? Name in politics? (I can't remember seeing this on sites, usually "Site / Forum Administration"), but this, it turns out, is not true ...
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It is logical not to do like everyone else, but to do it the right way ... open 152-FZ and read a couple of lines:
This Federal Law regulates relations related to the processing of personal data carried out by federal government bodies, state authorities of the constituent entities of the Russian Federation, and other state bodies (hereinafter - state bodies), local authorities, other municipal bodies (hereinafter - municipal bodies), legal entities and individualswith the use of automation tools, including in information and telecommunication networks, or without the use of such tools, if the processing of personal data without the use of such tools corresponds to the nature of the actions (operations) performed with personal data using automation tools ...
An agreement on the processing of personal data is an agreement between two or more parties, in the form of a public offer, the party to the agreement making the offer (being the operator of the PD) must be specifically defined (full name if it is a FL or the name of a legal entity ...), otherwise the agreement is not will be concluded, because the user of the site will not know with whom he concludes it ... if you indicate the administration of the site as a party, then additionally on the site you need to indicate who the administration is, with contact information.
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