Brazil: Consultation closed on Guidelines on the Processing of High-Risk Personal Data

On 28 September 2022, Brazil's National Data Protection Authority (ANPD) closed its consultation on the Guidelines on the Processing of High-Risk Personal Data. The Guidelines are intended to help data processors evaluate whether their processing practices meet the criteria for high-risk processing under Article 4 of the Law on General Personal Data Protection (LGPD). According to Article 4, to be classified as high-risk processing, an activity has to meet at least one general and one specific criterion. The general criteria involve either large-scale processing of data or processing which could significantly affect the rights or interests of the data holders. The specific criteria involve the use of new technologies, surveillance of public areas, automated decision-making, or sensitive personal data of children, adolescents and the elderly.