At minimum, your program calendar should reflect Law No. 13.709 publication on 14 August 2018, sanctions effectiveness for Articles 52 to 54 on 1 August 2021, Resolution CD ANPD No. 1 on 28 October 2021, Resolution CD ANPD No. 2 on 27 January 2022, Resolution CD ANPD No. 4 on 24 February 2023, Statement No. 1 on 22 May 2023, and Resolution CD ANPD No. 15 on 24 April 2024.
These milestones explain why some controls now require sharper operational evidence than older generic privacy programs assumed.