Template GuideArticles 18 and 19

Brazil LGPD DSAR Response Template

Use one response structure that matches the law and preserves evidence.

The template should support both the immediate simplified route and the 15 day complete declaration route.

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

Structured answer sets in this page tree.

Primary sources
2

Cited legal and guidance references.

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

A useful DSAR template is modular. It should capture identity verification, the right being exercised, the response format chosen, system coverage, legal rationale for any limitation, and the evidence needed to defend the answer later.

Section 1

Core response blocks

Every response should be assembled from a few stable blocks so teams can work quickly without skipping legal essentials.

  • Case metadata: request date, channel, case number, identity verification status
  • Rights classification: Article 18 item requested and whether Article 19 access logic applies
  • Response path: immediate simplified response or full declaration within 15 days
  • System coverage: which systems, processors, and business units were searched
Section 2

Mandatory legal content blocks

For access requests that go through the full declaration route, the response should state the origin of the data, whether records exist, the criteria used, and the purpose of processing, subject to commercial and industrial secrecy.

  • Origin of the data
  • Existence or absence of records
  • Criteria used for the processing or decision
  • Purpose of the processing
  • Explanation of any refusal, partial refusal, or delay
Section 3

Evidence blocks to retain with the sent response

The external message is not enough. Retain the operational proof that the organization checked the right systems and applied the right rule.

  • Identity verification proof
  • Search log or extraction log for the systems checked
  • Legal review note for denials or automated-decision cases
  • Copy of the final message sent to the data subject
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Section 4

Template quality controls

Review the template regularly against complaint patterns, reopened requests, and ANPD guidance updates so it stays usable and defensible.

  • Check whether teams are meeting the immediate and 15 day timing paths
  • Audit whether denials include lawful and clear reasons
  • Update child-data, processor, and automated-decision sections when guidance changes
Primary sources

References and citations

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