Artifact GuideBrazilTransfer Workflow

Brazil LGPD Transfer Workflow

Transfer Workflow decisions under the Brazil LGPD should be written in operational language: who is in scope, what must happen, what evidence proves it, and when escalation is needed.

Use this section to define scope, owner, evidence inputs, and the review outcome before execution.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
3

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

This page explains the Brazil LGPD international transfer workflow and helps teams decide whether a transfer can proceed, which legal path applies, and what evidence to keep before it goes live.

Section 1

How should a Transfer Workflow run under the Brazil LGPD?

Start by identifying the transfer path under Article 33: adequacy decision, contractual safeguards, corporate rules, certification or code, ANPD authorization, international cooperation, public policy or legal duty, consent, or another listed legal basis. If the transfer depends on Article 34 or Article 35 review, confirm the destination's protection level and the mechanism text before execution.

  • Capture the request, product, role, data flow, jurisdiction, and deadline.
  • Check the source-linked rule and route exceptions before implementation.
  • Record the action taken, owner, reviewer, evidence location, and next review date.
  • Keep a plain-language output that support, product, legal, security, and compliance teams can all understand.
Section 2

What fields should the Transfer Workflow template capture?

A useful template captures role, purpose, lawful basis, data subject, category, transfer or incident trigger, owner, evidence, and ANPD/DPO escalation note.

  • Source URL and source quote.
  • Entity, product, service, system, data category, and user group.
  • Decision result, control action, owner, reviewer, due date, and escalation reason.
  • Evidence attachment, approval note, exception note, and review cadence.
Section 3

How should teams review and improve the Transfer Workflow?

Review the workflow after ANPD guidance, new vendors, new purposes, cross-border changes, incidents, complaints, or changes to data-subject channels.

  • Track recurring exception categories and update intake questions.
  • Remove fields that never affect the decision.
  • Add fields when reviews show missing source evidence or unclear ownership.
  • Confirm the published page, internal playbook, and evidence template all give teams the same source-linked transfer guidance.
Primary sources

References and citations

gov.br
Referenced sections
  • ANPD guidance source explaining how transfer mechanisms protect personal data under LGPD standards.
"mecanismos para a transferência internacional de dados pessoais em conformidade com a LGPD"
planalto.gov.br
Referenced sections
  • Binding LGPD source supporting transfer-workflow review triggers for the Article 33 legal bases that permit international transfers of personal data.
"A transferência internacional de dados pessoais somente é permitida nos seguintes casos"
gov.br
Referenced sections
  • ANPD regulation source supporting transfer-workflow review triggers for transfer mechanisms, adequacy, contractual clauses, and transfer-governance evidence.
"aprova, na forma dos Anexos I e II, o Regulamento de Transferência Internacional de Dados"
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