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

On 16 May 2024, the National Data Protection Authority (ANPD) of Brazil closed its public consultation on the processing of high-risk personal data. The consultation aimed to clarify the concept of high risk and highlight its importance and refined 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 focused on defining high-risk processing in the context of rapid technological advancements and their implications for privacy and data subject rights. Specifically, the consultation was carried out in connection with draft Guidelines which provide criteria for high-risk processing, such as large-scale processing, automated processing, or sensitive data.