Artifact GuideBrazilTemplates

Brazil LGPD Templates

Choose the record from the legal event: routine processing, a data-subject request, a security incident, high-risk processing, an international transfer, or a role allocation.

A template is not an official ANPD form unless the authority says so. Adapt each record to the processing facts and keep the source, owner, decision, evidence, and review trigger.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

Use LGPD templates to make recurring decisions reproducible, not to replace the legal analysis. A or event-specific record should identify the controller or operator, processing and people in scope, applicable provision, decision, responsible owner, evidence, approval, deadline where one exists, and the facts that require review.

Section 1

Which LGPD template should a team use?

Use a for the recurring inventory required by Article 37; a data-subject request record for Articles 18-20; an incident assessment and communication record for Article 48 and Resolution 15/2024; a for high-risk processing or an ANPD request; an international-transfer record for Articles 33-36 and Resolution 19/2024; and a role record for controller, operator, sub-operator, and encarregado decisions.

Keep separate templates when the trigger, responsible actor, deadline, or required evidence differs. One generic compliance form tends to hide whether a request was answered, an incident threshold was tested, a transfer mechanism was valid, or a safeguard was actually implemented.

Use the ANPD's own incident communication form when filing a report, and preserve the filed version and protocol. The model published by government bodies is a working aid rather than a substitute for Article 38's minimum content or the controller's own risk analysis.

  • : purposes, legal bases, data and people, systems, sources, sharing, transfers, retention, security, roles, and owner.
  • Rights record: requester verification, right, scope, searches, response form, due date, decision, action, limitation, reviewer, and delivery proof.
  • Incident record: chronology, personal-data scope, relevant-risk-or-damage test, controller knowledge date, three-business-day clock, notices, any justified preliminary filing, the 20-business-day completion date, mitigation, and five-year retention.
  • , transfer, and role records: decision criteria, contracts or mechanisms, safeguards, residual risk, approval, and change triggers.
Section 2

What fields belong in every controlled template?

Start with stable identification fields: record ID and version, entity, controller and operator roles, product or process, purpose, people and data, source provision, owner, reviewer, decision date, and evidence location. Add the event-specific fields only after the applicable rule is known.

Distinguish a fact from a conclusion and a planned action from completed evidence. For example, a security-policy link does not prove that access was revoked, and an unsigned contract draft does not prove that an international-transfer mechanism is in force.

A rights template should not assign the 15-day Article 19 period to every Article 18 right. It should distinguish immediate simplified confirmation or access, a complete confirmation or access statement within 15 days, and other rights whose timing depends on the applicable ANPD or sector rule and the facts.

  • Scope: jurisdiction, role, purposes, legal bases, processing stages, systems, data, people, sources, recipients, transfers, retention, and deletion.
  • Decision: trigger, criteria, each conclusion, exception or limitation, accountable owner, reviewer, approval, and due date only where supported.
  • Evidence: source document, facts relied on, contract or notice version, system output, test result, delivery proof, filing protocol, and implementation status.
  • Lifecycle: open actions, residual risk, review date, change triggers, superseded version, and retention period.
Section 3

How should templates be approved and maintained?

Assign a content owner for the legal fields and an operational owner for the workflow. Test the template with a real scenario before release, confirm that every required decision can be recorded, and prevent users from selecting a deadline or legal conclusion without the supporting provision.

Review templates after a relevant law or ANPD regulation changes and after evidence shows recurring omissions. A new vendor, purpose, data category, transfer, automated decision, incident pattern, or role change may require a new record, not merely a revised blank form.

  • Version the template and completed record separately; do not overwrite the evidence used for an earlier decision.
  • Remove fields that never affect a decision, but retain legally required or independently useful evidence fields.
  • Update instructions and training when reviewers repeatedly misapply a deadline, role, threshold, or exception.
  • Treat ANPD forms and clause text as controlled source material; do not paraphrase mandatory wording into an internal substitute.
Primary sources

References and citations

gov.br3 citations
Referenced sections
  • Current ANPD regulation index and status for the topic-specific records described on this page.
  • Current ANPD index showing the status of Resolutions 2, 15, 18, 19, and later regulations used by the records on this page.
  • Current status index for the regulations that change incident, transfer, encarregado, and small-agent template fields.
planalto.gov.br3 citations
Referenced sections
  • Binding source for accountability, rights, transfers, processing records, RIPDs, roles, security, and incident communication.
  • Articles 18-20, 33-41, and 46-48 establish the distinct rights, transfer, record, RIPD, role, security, and incident records these templates support.
  • Article 6(X) requires measures that can demonstrate compliance and their effectiveness; the topic-specific provisions determine each record's content.
gov.br2 citations
Referenced sections
  • Simplified processing-record and related rules for qualifying small processing agents.
  • Article 9 permits a simplified processing record for qualifying small processing agents but does not remove the underlying accountability duty.
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Assign the reportability decision, knowledge timestamp, ANPD filing, affected-person notice, and follow-up evidence.

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Match each exporter, importer, onward flow, and processing basis to the selected Article 33 mechanism.

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Record each purpose, data category, statutory basis, necessity, notice, retention, and reassessment trigger.

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Document the interest, necessity, alternatives, expectations, impacts, effective safeguards, and approval.

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Assign the report trigger, processing description, risk assessment, safeguards, controller decision, and mitigation checks.

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Verify eligibility, group revenue, the two-part high-risk screen, each flexibility used, and continuing duties.