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Правовое регулирование защиты персональных данных в РФ и ЕС в контексте вступления в силу Общего Регламента по защите данных (GDPR)
The article is devoted to the analysis of the state of the Russian and European legislation on personal data in connection with the entry into force of the Regulation (EU) 2016/679 of the European Parliament and of the Council from 27.04.2016, better known as GDPR. GDPR Regulation is being considered in comparison with Federal Law No. 152-FZ «On Personal Data», as a special regulatory legal act regulating the legal institution in question in the Russian Federation. It is concluded that the Russian legislation on personal data contains some shortcomings, in particular, the lack of an independent body to control the protection of personal data, which can be offset by borrowing the relevant provisions from the GDPR Regulation and the subsequent harmonization of legislative regulation in this area in the future.