The list of data that employers are required to provide includes the following information about an employee:
- Mobile number;
- Numbers of travel cards "Troika" and "Strelka";
- Car number;
- Numbers of social cards and temporary discount tickets for public transport.
Additionally, the employer will need to provide the following information about the company:
- Company name;
- Number in the Russian Register of legal entities;
- Codes of business activity (OKVED);
- legal address;
- total number of employees;
- the number of employees transferred to remote work mode.
It is noteworthy that according to the statement of the Department of Information Technologies of the Moscow City Governement, this information is not personal data, because it does not contain full names of the employees and, using this information, it is impossible to establish their identity.
However, personal data is any data directly or indirectly related to an individual who can be identified (if the data is not anonymized). Based on judicial and law enforcement practice, personal data includes not only full name or passport details of an individual, but also information such as the location of a person determined by Internet sites and mobile applications, or details of bank card.
In this regard, we recommend that you adhere to the requirements of the Russian legislation on personal data when transferring them via the mos.ru website. Since the data of employees is transferred in order to prevent the threat to their life and health caused by coronavirus infection, the written consent of employees for the transfer of this data is not required in accordance with Art. 88 of the Labor Code of the Russian Federation. However, employees must be notified of such data transfer and specific categories of data that are disclosed to the Moscow City Government.