Policy Briefing — Brazil’s LGPD enters into force with immediate controller obligations
Brazil’s Lei Geral de Proteção de Dados became effective on 18 September 2020, activating lawful basis, transparency, data subject response, and processor oversight duties ahead of administrative sanctioning in August 2021.
Executive briefing: With Law No. 13.709/2018 now in effect, controllers must establish legal bases for processing, update privacy notices, respond to access and deletion requests, and monitor processors under Articles 37–39. While ANPD fines begin 1 August 2021, civil actions and public prosecutor scrutiny started immediately, making evidence of governance controls essential.Articles 7–10, 18, 37–41
Compliance actions
- Record keeping. Stand up Article 37 processing records and contract clauses covering security, breach notification, and sub-processor approvals.
- Rights response. Build intake and response playbooks for access, correction, deletion, portability, and revocation requests within statutory deadlines.
- Data protection officer. Designate a DPO, publish contact details, and set escalation routes to the ANPD for high-risk processing.
Sources
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