Policy Briefing — Brazil LGPD Sanctions Enforcement Begins
Brazil’s General Data Protection Law entered its administrative sanction phase, empowering the ANPD to levy fines and corrective orders for non-compliance.
Executive briefing: August 1, 2021 triggered the sanctioning phase of Brazil’s Lei Geral de Proteção de Dados (LGPD), enabling the Autoridade Nacional de Proteção de Dados (ANPD) to impose fines up to 2% of a company’s Brazilian revenue (capped at BRL 50 million per infraction) and issue corrective measures for violations.
Immediate compliance priorities
- Sanction exposure review. Revisit LGPD compliance assessments to close outstanding remediation items before ANPD supervisory actions.
- Incident readiness. Validate breach notification playbooks covering ANPD reporting timelines and communication templates for data subjects.
- Vendor accountability. Refresh processor contracts to evidence shared responsibilities, audit rights, and data localisation controls.
Control alignment
- Governance. Confirm Data Protection Officers are registered with ANPD and maintain compliance dashboards for leadership.
- Training. Deliver refresher courses for frontline staff on lawful bases, consent management, and data subject rights workflows.
- Monitoring. Implement metrics tracking request fulfilment, incident response times, and third-party assessments to support ANPD audits.
Enablement moves
- Engage Brazilian counsel to interpret forthcoming ANPD sanctioning regulations and methodology.
- Benchmark privacy controls against ANPD’s inspection checklists and sectoral guidance.
- Integrate LGPD posture reporting into enterprise risk management and board updates.
Sources
- ANPD announcement on launching the LGPD sanctioning phase
- Law No. 13.709/2018 — General Data Protection Law (LGPD)
Zeph Tech strengthens LGPD programmes with sanction readiness roadmaps, ANPD engagement scripts, and high-priority remediation tracking.