Rights GuideArticles 18 to 20

Brazil LGPD Data Subject Rights

Run rights operations around the actual LGPD response structure.

The law expects free requests, immediate simplified confirmation or access when possible, a full declaration within 15 days, and a defensible workflow for denials and automated decision review.

Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 21, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Feb 21, 2026
Overview

Articles 18 to 20 create the core rights stack. Controllers need to support confirmation of processing, access, correction, anonymization, blocking, deletion, portability, information on sharing, information about consent consequences, consent revocation, and review of decisions made solely by automated processing.

Section 1

Map every Article 18 right to one operational route

Rights quality fails when the same request is handled differently across channels or business units. Build one taxonomy and one routing model for confirmation, access, correction, anonymization, blocking, deletion, portability, sharing information, consent information, and consent revocation.

Keep special handling rules for requests involving processors, archived records, or legal retention constraints.

  • Tag the request with the specific right being exercised
  • Map the systems, processors, and teams needed for fulfillment
  • Record any legal basis for refusal, limitation, or deferred action
Section 2

Use the Article 19 response format correctly

For confirmation of existence or access, Article 19 gives two formats. The controller can provide a simplified response immediately, or a clear and complete declaration within 15 days that explains origin of the data, existence or absence of records, criteria used, and processing purpose, subject to commercial and industrial secrecy.

The right is exercised without cost to the data subject, and the information can be provided electronically or in printed form at the data subject choice.

  • Offer an immediate simplified response path when feasible
  • Maintain a 15 day full declaration path for complete responses
  • Store the evidence showing which systems and processors were checked
Section 3

Control deletion, portability, and revocation edge cases

Deletion under Article 18 is not automatic in every case. Data processed under consent can be deleted subject to the Article 16 retention exceptions, and portability does not include data already anonymized by the controller.

Consent revocation must be supported by a free and easy procedure, and changes should be communicated to other agents with whom the data was shared unless impossible or disproportionate.

  • Check Article 16 retention grounds before deleting data
  • Exclude already anonymized data from portability exports
  • Notify shared-use partners about correction, deletion, anonymization, or blocking when required
Section 4

Treat automated decision review as a separate workflow

Article 20 gives the data subject the right to request review of decisions taken solely on automated processing that affect the data subject interests. The controller must also provide clear and adequate information on the criteria and procedures used, subject to commercial and industrial secrecy.

If secrecy is invoked, ANPD can audit the system for discriminatory aspects. That makes model governance and review evidence essential.

  • Keep a trigger to identify purely automated decisions
  • Prepare explanation records about criteria and procedures used
  • Escalate secrecy-based refusals for legal review because ANPD can inspect
Recommended next step

Use Brazil LGPD Data Subject Rights as a cited research workflow

Research Copilot can take Brazil LGPD Data Subject Rights from clarifying scope and applicability with cited answers to a reusable workflow inside Sorena. Teams working on Brazil LGPD can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Primary sources

References and citations

in.gov.br
Referenced sections
  • Official ANPD interpretation on legal bases for children and adolescents data under Article 14.
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