In these three countries, employee consent may be the only way to transfer their data

Before a deep dive into the issues of employee data processing and transfer, it is worth examining the requirements for employment documentation in Russia, Belarus, and Ukraine.

Generally, paper files remain the prevailing form of such documentation, and they are extensively used by local companies to demonstrate compliance to state regulators. Among other purposes, employee records maintained in a prescribed way present a proof of proper employee data collection allowing its further processing.

Source: In these three countries, employee consent may be the only way to transfer their data