Data Strategy Briefing — February 14, 2025
Brazil's ANPD is scheduled to finalise international data transfer rules in Q1 2025, requiring global privacy leaders to align contractual clauses, risk assessments, and enforcement reporting channels ahead of publication.
Executive briefing: The ANPD's 2024-2025 regulatory agenda targets first-quarter 2025 completion of rules governing international personal data transfers, including model contractual clauses, adequacy mechanisms, and transfer impact assessment guidance. Multinational organisations should prepare to adopt ANPD-sanctioned clauses and update cross-border governance programmes immediately once the resolution issues.
Key governance checkpoints
- Transfer inventory. Catalogue Brazil-related data flows, highlighting high-risk processing (financial, biometric, children's data) that may trigger enhanced assessment obligations.
- Contract readiness. Draft fallback clauses aligning with LGPD Articles 33-36 so agreements can be updated quickly once ANPD publishes standard clauses.
- Impact assessments. Develop templates for transfer impact assessments that evaluate foreign jurisdiction protections, technical safeguards, and redress mechanisms.
Operational priorities
- Regulatory monitoring. Assign staff to track the ANPD consultation and final vote, capturing deviations from initial agenda assumptions.
- Stakeholder alignment. Coordinate legal, security, and procurement teams on remediation sequencing once rules take effect.
- Evidence management. Build repositories storing assessments, contractual updates, and technical safeguard descriptions to satisfy ANPD audits.
Enablement moves
- Engage with industry associations drafting collective feedback on the forthcoming resolution to align sector-specific needs.
- Map ANPD requirements to EU SCCs and UK IDTA obligations to streamline multi-jurisdiction transfer governance.
Sources
Zeph Tech readies LGPD programmes for ANPD transfer rules with clause playbooks, risk assessment tooling, and audit-ready evidence packs.