FZ-152 (Federal Law "On Personal Data") How not to receive congratulations on the New Year from the FSTEC?

Question

Data recovery

Suitable January 1, 2011, which means that the law FZ-152 comes into full force. It has already been written about him several times on Habré, but many questions and ambiguities remain.
I would like to contact legally savvy specialists.
A typical site with an online store. 50,000 users, from the Full Name + Phone + Address data, it looks like Class 2, which means that global events are mandatory.
Will we violate something in the Russian Federation:
1) If we move to hosting abroad? Will the fact that a legal entity is registered in the Russian Federation, for example, have to do with this?
2) If we add all the data to a third-party server certified in the 1st class and request them in some batches from this server? For example, you will have to request data from the server to make an application for an order and transfer it to the delivery service. Or to compile a list of SMS mailing lists, where user data will be required in bulk?

What are the possible ways to circumvent the holding of "events" in accordance with Federal Law-152.

Answer 1

The law came into force in January 2007. So no one removed the responsibility for storing PD.
Another thing is that your IP must comply with the requirements of FZ-152.
According to the latest information, it was again amended and the adoption of compliance was postponed until July 1, 2011.

Answer 2

Have you read Temko on Habré ..?
habrahabr.ru/blogs/infosecurity/109519/

Answer 3

About moving the server abroad. The law has subtleties about cross-border (across the border of the state) data transfer, so not everything is obvious here.
But given that confirmation of the consent to the transfer of PD through an electronic form requires an EDS or a written application from a citizen (you won’t believe it, but this is exactly what the by-laws from the FSTEC and the company require ..) 152 the law is obviously unrealistic to fulfill on the Internet.