Artifact GuideBrazilData Subject Rights

Brazil LGPD Data Subject Rights

Data Subject Rights under the Brazil LGPD mean giving people a clear way to confirm, access, correct, delete, move, object to, or review how their data is handled.

Use this section to define the request type, owner, evidence, and timing before you respond.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

This page explains the main LGPD rights in Article 18 and the response path in Article 19 so teams can handle requests with clear owners, evidence, and deadlines.

Section 1

What should teams decide about Data Subject Rights under the Brazil LGPD?

Start by identifying which Article 18 right is being requested: confirmation of processing, access, correction, anonymization, blocking or deletion, portability, deletion after consent, information about sharing, information about refusing consent, revocation of consent, or a complaint to the ANPD. The response should match the request and the legal basis for the data being processed.

For confirmation or access, Article 19 says the controller must respond immediately in simplified form or within up to 15 days with a clear and complete declaration. For practical handling, capture the request date, identity check, owner, response format, and any legal reason that limits full disclosure.

  • Confirm which Article 18 right the person is using.
  • Record the controller, the data set, and whether the request is for simplified confirmation, full access, correction, deletion, portability, or another remedy.
  • Use the Article 19 timing rule: immediate simplified confirmation or a complete response within 15 days.
  • If the request cannot be fulfilled right away, explain the reason and keep the record of the reply and any follow-up action.
Section 2

Who should own Data Subject Rights, and what evidence should prove the decision?

Ownership should sit with the team that controls the processing purpose and the customer channel that receives the request, with privacy or legal review when the answer depends on an exception or a conflict with another legal duty.

Evidence should show the request log, identity check, the Article 18 right involved, the response sent, the date of response, and any action taken to correct, delete, block, or share the request with other controllers when required.

  • Name one accountable owner and one reviewer for the Data Subject Rights workflow.
  • Keep the request record, reply text, supporting tickets, and approval notes together.
  • Use dated evidence for the request date and the Article 19 deadline.
  • Review the evidence after product changes, new data uses, or updates to the official source text.
Section 3

Which edge cases should teams check before relying on a Data Subject Rights decision?

Most LGPD mistakes happen when teams miss the difference between a full access request and a narrower correction, deletion, or portability request, or when they fail to identify whether another law limits disclosure.

Apply this section before approving a response. If the request involves another controller, a public-body process, a child-data request, or a decision on automated profiling, route it for legal review and keep the request open until the response can be accurate.

  • Check whether the request is for confirmation, access, correction, anonymization, blocking, deletion, portability, or revocation.
  • Separate what must be answered immediately from what can be answered within 15 days.
  • Do not rely on a previous answer if the data set, purpose, or request type changed.
  • Track unresolved assumptions and route legal interpretation points for review.
Section 4

How should teams operationalize Data Subject Rights with proportionate controls?

Use a simple workflow that logs the request, confirms identity, identifies the Article 18 right, assigns an owner, and records the answer date. For confirmation or access, the reply should be immediate in simplified form or within up to 15 days as a clear and complete declaration.

Where the request requires action, the workflow should also trigger correction, deletion, blocking, anonymization, portability, or sharing of the request with other controllers when the law requires it.

  • Create a short intake question that identifies the Data Subject Rights scenario.
  • Map the answer to a required action, evidence field, owner, reviewer, and due date.
  • Link related artifact pages with descriptive anchors so users can move from rights to deadlines, controls, penalties, and templates.
  • Update the workflow when official source material changes or when internal evidence shows recurring exceptions.
Primary sources

References and citations

gov.br
Referenced sections
  • ANPD guidance explaining confirmation, access, correction, deletion, portability, objection, and review rights that shape Brazil LGPD request workflows.
"confirmação sobre a existência de um tratamento de seus dados"
planalto.gov.br
Referenced sections
  • Primary LGPD source for Article 18 rights and Article 19 response timing.
"Art. 19. A confirmaçao de existência ou o acesso a dados pessoais serao providenciados, mediante requisiçao do titular"
gov.br
Referenced sections
  • ANPD regulation used for evidence about petitions by data subjects after a controller has not resolved a request in the regulatory timeframe.
"petição de titular: comunicação feita à ANPD pelo titular de dados pessoais"
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