Brazil LGPD penalties and fines

LGPD Article 52 says agents of treatment are subject to administrative sanctions applied by the national authority (ANPD). The main penalties include warning, a simple fine of up to 2% of the private legal entity's revenue in Brazil in its last fiscal year, limited to R$ 50,000,000.00 per infraction, a daily fine, publication of the infraction, blocking of the personal data, elimination of the personal data, suspension of the database or processing activity, and partial or total prohibition of data-processing activities.

Start by deciding whether the issue affects controller/operator roles, lawful basis, data-subject rights, children data, international transfers, security incidents, DPO/encarregado duties, or ANPD enforcement exposure. Then name the exact trigger, affected product or process, required action, owner, evidence, and escalation point.

Ownership should sit with the team that controls the processing purpose, data-subject channel, vendor relationship, transfer mechanism, security incident response, or ANPD communication.

Evidence should show controller/operator mapping, lawful basis, transparency notice, rights response, transfer analysis, incident decision, DPO involvement, and ANPD remediation record where applicable.

Most LGPD mistakes happen at the boundary between controller and operator duties, consent and other lawful bases, academic or public-interest processing, international transfers, and incident notification thresholds.

Apply this section before approving a processing activity, vendor arrangement, transfer, rights workflow, child-data handling, or incident response under LGPD. If evidence is missing, block progression and raise a review task.

Use an LGPD workflow that captures role, purpose, lawful basis, data category, data-subject right, transfer or incident trigger, DPO review, evidence, and review date.

The output should be a lawful-basis memo, role map, privacy notice update, DSAR record, transfer note, incident assessment, or ANPD response pack.