Brazil: Opened ANPD Consultation on High-Risk Personal Data Processing

On 17 April 2024, the National Data Protection Authority (ANPD) of Brazil opened a public consultation to gather insights on the processing of high-risk personal data. The consultation remains open until the 16 May 2024 and aims to clarify the concept of high risk and highlight its importance and refine guidelines supporting the evaluation of high-risk situations in personal data processing, as outlined in the Regulation for the application of the LGPD by small processing agents (ATPP). The consultation focuses on defining high-risk processing in the context of rapid technological advancements and their implications for privacy and data subject rights. Specifically, the consultation is carried out in connection with draft Guidelines which provide criteria for high-risk processing, such as large-scale processing, automated processing, or sensitive data.