Does 152-FZ apply to the self-employed
Self-employed (НПД) is a tax regime, not an exemption from 152-FZ. Once you systematically collect customer names and phone numbers — via a landing page, a booking spreadsheet or chats — you process personal data commercially and qualify as an operator. That means: a policy, consent at the point of collection, and a Roskomnadzor notification. Fines for individuals are lower than for businesses, but the duties are identical.
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Where the line runs
152-FZ does not cover processing for personal and family needs: saving a friend's number is not processing. But regularly taking client requests is a business context, and the НПД tax regime changes nothing. An individual can be an operator — the law explicitly allows it.
- A landing page with a booking form — personal-data processing
- A Google form or client spreadsheet — processing
- A chat-bot collecting a name and phone — processing
The minimal document set
Smaller than a corporate stack but mandatory: a short processing policy (who you are, what you collect and why, who receives it, how long you keep it), a consent text, and a policy link at every collection point. The RKN notification can be filed by an individual — the portal form supports it. If requests land in a foreign service (Google Forms, Notion), cross-border transfer questions appear — a Russian tool is simpler.
A quick self-check
If you have a site or landing page, run it through the compliance scanner: it shows forms without consent, a missing policy and foreign trackers. Free, takes under a minute, and the report reads without a lawyer.
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Why check your site for privacy compliance?
Regulators fine sites for processing personal data without consent — and a site starts processing earlier than it seems: analytics, pixels and widgets write cookies the moment the page loads. The scanner shows the auditor's view: what leaves for third parties before consent, whether the banner works, and whether forms collect data correctly.
Real Browser
Three sessions per page: no action, banner accepted, banner rejected.
Trackers and Jurisdiction
Service catalogue: who receives visitor data and in which country.
Policy at Collection Point
The policy link and consent element are checked next to the form, not in the footer.
Signed PDF
Report with an HMAC integrity stamp — hand it to your lawyer or contractor.
Who uses this
Business
preparing for an audit
Lawyers
technical facts for an opinion
Web Studios
client site handover
DevOps
consent regression monitoring
Common Mistakes
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Scheduled re-checks with an alert when pre-consent trackers appear on your site.
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Frequently Asked Questions
I take requests only in DMs. Is that processing too?
Yes, if you keep customer contacts to work with them. The messaging platform does not cancel your role as the operator of the collected data.
What happens if I just do nothing?
The risk is an unhappy client's complaint to RKN and an inspection. Individual fines are moderate, but a remediation order and a ban on collection paralyse the site.
If I register as a sole proprietor, what changes?
The duties stay the same; the liability grows: under the note to Art. 13.11 a sole proprietor is fined as a legal entity. Documents made now remain valid.
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