RKN: Using analytics can lead to site blocking.

Incorrect use of Google Analytics and Yandex Metrics analytics services may result in restricted access to the site, Roskomnadzor said. 3r3386.  
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The Tagansky Court of Moscow on December 19 at the suit of Roskomnadzor to the French domain registrar Gandi SAS 3r-38c. ruled 3r3–3100. about blocking the site of "collective voting" 2019.vote. Earlier, on December 1? 3r3-10 was published. Solution 3r3-300. about adding a site to the registry of violators of PD handlers as an interim measure on the lawsuit, and from December ? 2013 began. Restriction of access to the site by providers 3-333100. :
 
The representative of Roskomnadzor explained that at the end of November, the site received complaints from several unnamed citizens who complained about the illegal processing of their data on the “smart voting” page. After that, employees of the department conducted their own inspection, which confirmed the existence of violations of the law on personal dаta: the form for collecting data on the Navalny website did not meet the criteria specified in the law, moreover, there was no written privacy policy on the resource. Ampellonsky also added that user data is stored on foreign servers, which is against the law. 3r3365. 3r318. 3r3-300. 3r3386.  
In a meeting on December 1? as one of the arguments, the plaintiff cited the fact that the site uses Google Analytics and Yandex Metrics analytics systems in violation of the Personal Data Protection Act and the Terms of Use. As proof, photos of the site’s HTML code in Opera’s browser were provided. This information today RKN confirmed in an official press release on its website 3-333100. :
 
We are talking about the requirements of the Federal Personal Data Act and the GoogleAnalytics Terms of Use, which require the site administration to collect personal information about visitors to this site to notify them about the data collection, obtain consent for their processing and post a document regulating the privacy policy . 3r3386.  
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However, these requirements by the site administrator 2019.vote were not met. 3r3386.  
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Thus, it was not about the claims of Roskomnadzor to the metric programs of Google, OOO Yandex, but about the non-fulfillment by the site administrator 2019.vote of the requirements of the metric programs GoogleAnalytics, Yandex.Metrica specified in the Terms of Use. 3r3386.  
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In this connection, the Tagansky District Court of the city of Moscow for non-compliance, including the above requirements, decided to restrict access to the site until the violations were remedied. 3r3365. Unfortunately, the press release did not clarify exactly which categories of “personal data” analytics services collect. So, when studying the official site of the RKN, you can find comments that say that the name, phone number or email may not be personal data, and the counters collect less sensitive data such as IP addresses (they do not give you the entire view). For example, 3r340. Full names are not considered as PDs 3r3-3100. :
 
3. Question: Is the processing of personal data the placement of the last name, first name and patronymic without any additional information? 3r3386.  
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Answer: Placing on the pages of sites on the Internet the last name, first name and patronymic without additional information that allows identifying an individual as a subject of personal data cannot indicate the processing of personal data of a particular individual. 3r3365. Phone number from 3r350. point of view of the ILV 3r3-3100 is not PD:
 
Question: Is the processing of personal data, making phone calls to conduct telephone surveys of citizens? 3r3386.  
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Answer: According to Art. 3 of the Federal Law of July 2? 2006 No. 152-ФЗ “On Personal Data” personal data is any information relating to a directly or indirectly determined or determined individual (subject of personal data). The subscriber number (telephone number) is the number allocated to the subscriber (set of numeric characters) when entering into an agreement on the provision of telephone services with the subscriber. This number is used to indicate the possibility of identifying the end equipment of the subscriber in the communication network when the subscriber devices are connected to it, which means that the telephone number without indicating its owner is not information on the basis of which this person (personal data subject) can be uniquely identified and its use may not imply the processing of the personal data of its owner. 3r3365. Also
does not count as PD and email address
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For example, a photo, name, phone number and email address allow you to identify a person quite accurately. A photo and the name “Olya” cannot be considered personal data, as well as a single e-mail address or phone number. It is about the aggregate data. 3r3365. Unfortunately, many sites that use analytics services do not notify visitors, and do not get their consent to data collection. Such sites, in order to avoid blocking, should urgently take measures to remedy the situation. For example, if you open the source code of the site "Server of public authorities of the Russian Federation" 3r3666. gov.ru
, you can see the use of “Google Analytics” and “Yandex-metrics”, while the warning about data collection is not displayed and the user's consent to collect data is not asked. 3r3386.  
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We do not ask for consent to the collection of data and on the website 3r372. the United Russia party 3-33–3100. where the services “Live Internet”, “Yandex-metric”, “Facebook Pixel” (2 copies), “Rambler Top 100” are installed. There is no such thing on the Vesti.ru website, where a pleiad from Piwik, Adblockmetrics, [email protected], Yandex-metrics, LiveInternet, Google Analytics, as well as and ad networks "AdFox", "1banner". They are not far behind the “second” of their colleagues from r3r374. The “first” 3r3–3100. channel - on their website there are “undeclared” “LiveInternet Counter”, “Yandex-Metric”, “Google Analytics”, and widgets from Facebook, VK, Odnoklassniki, Twitter, also collecting analytics. 3r3386.  
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It is worth noting that a full-fledged blocking of the site’s work on the territory of the Russian Federation is not yet provided. According to some users, the site is available from their providers when using Google’s ???.8 DNS server. Judging by the records ( From ???-33-300. 3r3386.  
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Habrupt users using analytics services are advised to check if the regulator’s requirements are met on their sites.
Only registered users can participate in the survey.
Enter
, you are welcome.
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3r3108. Do you ask for consent to collect analytics data on your website? 3r3189.
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3r3188. No, but I’m warning you about the collection of information in regular 3r3189.
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3r3188. Yes, I fulfill all the listed ILV requirements 3r3189.
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3r3188. I do not keep track of my users
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3r3188. Why do you ask? 3r3189.
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3r3188. I do not have a site
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3r3r2202. 35 users have voted. Abstained 14 users.
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