Google App Engine and FZ-152 "On Personal Data"?

Question

Law in IT

Some of the “personal data operators” and / or developers of the “ISPD”, or maybe from the Google employees present here, analyzed the possibility of using GAE for storing / processing PD (full name, passport data, including registration at the place of residence and stay, telephones, soap, IM) of clients (individuals) of a legal entity / individual entrepreneur (customer of the system) in the light of FZ-152?
What additional difficulties can arise for both the customer and the developer compared to such a system in a local environment developed on their own? And if the developer will provide such a system to the customer as SaaS? Or is the use of GAE not realistic at all, since it is impossible even to check, let alone certify, the GAE infrastructure for compliance with Federal Law-152?
PS Processing PD is not the main function of the system, the main one is operational accounting, but other laws and regulations require the customer to process PD, and it’s just convenient to identify the client by full name, and not, for example, by order number or regular customer card.
PPS There are different thoughts about bypassing the FD, for example, store PD locally, and the rest in GAE, for example, in localStorage html5, but, as I understand it, there is no easy way to synchronize localStorage either between different workstations of one user, or between different users - maybe another option for exchanging data between users for a system with a web face without using publicly available servers (and ideally without servers with data). Can store PDs in the GAE vault encrypted with keys stored locally?

Answer 1

As far as I learned in a recent topic on Habré, the storage of PD abroad is not subject to the laws of the Russian Federation.