Data Strategy Briefing — February 8, 2024
Brazil's data protection authority approved its 2024-2025 regulatory agenda, locking in timelines for international transfer rules, children's data safeguards, and high-risk processing assessments.
Executive briefing: On 8 February 2024 the Autoridade Nacional de Proteção de Dados (ANPD) approved Resolution CD/ANPD No. 15/2024, publishing a two-year regulatory agenda that sequences priority rulemakings across international transfers, anonymisation, children's data processing, and incident reporting refinements. Data leaders operating in Brazil must align compliance roadmaps to the agenda's quarterly milestones, prepare evidence for small-agency obligations that transition in 2024, and stage budget requests around anticipated sandbox and high-risk assessment guidance.
Key governance checkpoints
- Roadmap reconciliation. Map ANPD agenda phases against existing LGPD controls, calling out where draft rules on international transfers and anonymisation require new legal bases or vendor attestations.
- Risk classification. Inventory processing operations that may fall under forthcoming high-risk assessment rules, prioritising biometrics, credit scoring, and geolocation analytics.
- Incident response upgrades. Compare current notification playbooks with the agenda's plan to refine breach reporting requirements, ensuring controllers can deliver evidence packages within ANPD deadlines.
Operational priorities
- International transfer governance. Begin negotiating contractual clauses and transfer impact assessments in anticipation of model clauses the ANPD plans to finalise by early 2025.
- Children's data controls. Launch design reviews on parental verification, proportionality, and content moderation workflows ahead of proposed rules entering consultation in late 2024.
- Stakeholder monitoring. Assign regulatory affairs staff to track public consultations and technical studies the agenda schedules each quarter, feeding outcomes into policy and engineering sprints.
Enablement moves
- Brief Brazilian executives on the agenda's sequencing so resource planning anticipates when new obligations will crystallise.
- Engage industry associations preparing joint submissions on international transfer rules to amplify sector-specific requirements.
Sources
Zeph Tech equips LGPD programs with agenda-aware backlogs, consultation trackers, and evidence frameworks tailored to ANPD enforcement.