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Cybersecurity and continuity

Business continuity and data protection: 152-FZ and fines for data leaks

A data leak damages reputation, and it also brings legal risk and fines. We look at the link between continuity and data protection, the requirements of Federal Law No. 152-FZ, and how to reduce the risk with simple measures.

Updated: 28 June 2026 · Author: Evgeny Telenkov · ≈ 6 min read

Why data is a continuity issue

Loss or leak of data can stop processes (people have nothing to work with) and lead to legal consequences. This is why data protection is part of both cybersecurity and business continuity. The target for acceptable data loss (RPO) is set in the BIA and met through backups (DRP).

What Federal Law No. 152-FZ requires

Federal Law No. 152-FZ “On Personal Data” requires operators to protect personal data, restrict access, respond to incidents and, in some cases, notify the regulator. Violations and leaks carry liability, and the law is moving towards stricter rules and turnover-based fines (linked to revenue). This moves the risk out of the “technical” category and into “money and the owner's responsibility”.

Important: the exact amounts and wording of fines change. Check the current version of the law or ask a lawyer before you make decisions.

Basic measures to reduce the risk

  • Minimisation: keep only the data you need and restrict access.
  • Backups, including isolated ones.
  • An incident and data leak response plan (see “what to do in a cyberattack”).
  • Staff training and basic cyber hygiene.

Company data: threats and continuity measures

Data typeMain threatContinuity measure
Customer baseRansomware, theft, accidental deletionBackups under the 3-2-1 rule, recovery test
Financial dataLoss of access to the accounting systemRPO of no more than one day, exports of key reports
Documents and contractsA single copy on one diskCloud plus an offline copy, version control
Access rights and passwordsThe administrator leaves, keys are lostCompany password manager, duplicated access rights
Personal dataLeak and fines from the regulatorStorage minimisation, encryption, notification plan

Frequently asked questions

What are the fines for personal data leaks?

Liability under Federal Law No. 152-FZ is getting stricter. Turnover-based fines (linked to revenue) are being discussed and introduced. The exact amounts depend on the current version of the law, so check the legislation in force or ask a lawyer.

How are data protection and business continuity linked?

Data loss stops processes and creates legal risk. Business continuity sets the acceptable data loss (RPO) and makes sure data can be restored from backups.

Is your team ready for the first hour of a crisis?

You test a plan by running a scenario. Reading it is not enough. The assessment shows the gaps, and the corporate format works through them with your team on your own processes.

Evgeny Telenkov
Director, Business Continuity Practice · PhD in Economics · Academic Director and Chief Examiner
Best Risk Manager of Russia 2020 (RusRisk). Built business continuity at Nornickel from scratch. Author of more than 30 continuity plans. Worked in the risk functions of Beeline, Rosneft and EY. Chief Risk Officer of a USD 20 billion petrochemical megaproject. Deputy Chair of Rosstandart Technical Committee 010 “Risk Management”, co-author of six GOST R standards. Author of the ERGP and SAFE programmes.
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