What transfer mechanisms are allowed under the Brazil LGPD?
Teams should treat international transfers under the Brazil LGPD as a source-linked operating decision: confirm whether the transfer can rely on adequacy, contractual safeguards, binding corporate rules, consent, legal necessity, public policy, ANPD authorization, international cooperation, or other cases listed in Article 33, then assign the team that can change the process and keep evidence showing the action and review trigger.
The first step is to identify the transfer base in Article 33 and match it to the data flow before execution.
- Adequacy: transfer to countries or international organizations that provide an adequate level of personal data protection recognized by ANPD.
- Contractual safeguards: specific contractual clauses, standard contractual clauses, or binding corporate rules when the controller proves compliance with LGPD principles, data subject rights, and the data protection regime.
- Other Article 33 cases: cooperation between public bodies, protection of life or physical integrity, ANPD authorization, international cooperation agreements, public policy or legal attribution, specific consent, or the hypotheses in Article 7 or Article 11.
- Keep the legal basis, the mechanism used, and the source quote together in the evidence record.
Primary LGPD source for the legal mechanisms that permit international transfers of personal data from Brazil.
ANPD regulation source for international transfer procedures, standard contractual clauses, and related transfer mechanisms under the LGPD.
ANPD source showing regulatory treatment of international transfers and standard contractual clauses under the LGPD.