APPI
Japan's law regulating personal data handling and protection
LGPD
Brazil's regulation for personal data protection.
Quick Verdict
APPI governs Japan's personal data with PPC oversight and ¥100M fines, while LGPD mandates Brazil's data protection via ANPD with 2% revenue penalties. Companies adopt APPI for Japanese market access and LGPD for Brazilian compliance to avoid fines and build trust.
APPI
Act on the Protection of Personal Information
Key Features
- Extraterritorial scope targets foreign businesses
- Pseudonymously processed data enables analytics
- Explicit consent for sensitive transfers
- Four-tier security controls mandatory
- PPC fines up to ¥100M
LGPD
Lei Geral de Proteção de Dados Pessoais (Law 13.709/2018)
Key Features
- Extraterritorial scope targeting Brazilian residents globally
- 10 core principles including prevention and non-discrimination
- Data subject rights with anonymization and portability
- Fines up to 2% Brazilian revenue enforced by ANPD
- Mandatory SCCs for cross-border transfers by 2025
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
APPI Details
What It Is
Act on the Protection of Personal Information (APPI) is Japan's primary data protection regulation, enacted in 2003 with major amendments in 2022. It governs handling of personal data by businesses, balancing privacy rights with economic data use through risk-based principles like purpose limitation and security controls.
Key Components
- Core pillars: consent management, data subject rights (access, correction, deletion), security safeguards, cross-border transfers.
- Distinguishes sensitive and pseudonymously processed information.
- Enforced by Personal Information Protection Commission (PPC) with fines up to ¥100 million.
- No mandatory certification but recommends DPO appointment.
Why Organizations Use It
Mandatory for entities handling Japanese residents' data; drives compliance to avoid fines, reputational harm. Offers **strategic benefitsbuilds consumer trust (78% prefer compliant brands), enables cross-border flows, reduces risks via structured governance yielding 20-30% efficiency gains.
Implementation Overview
Phased 12-24 month framework: gap analysis, policy design, technical controls, testing, monitoring. Applies to all sizes/industries targeting Japan; SMEs lighter touch, enterprises full GRC integration. No certification required but PPC audits common.
LGPD Details
What It Is
Lei Geral de Proteção de Dados Pessoais (LGPD), Law No. 13.709/2018, is Brazil's comprehensive data protection regulation. Enacted in 2018 and fully enforced since 2021, it safeguards personal data of Brazilian residents with extraterritorial scope, applying to any processing targeting them or occurring in Brazil. It adopts a risk-based approach with 10 core principles like purpose limitation, necessity, and accountability.
Key Components
- 10 principles governing all processing activities.
- Data subject rights (access, correction, deletion, portability, anonymization).
- Legal bases (10 options including consent, legitimate interests).
- Governance via mandatory DPO for controllers, DPIAs for high-risk processing, records of activities.
- ANPD enforcement with graduated sanctions; no formal certification but compliance audits.
Why Organizations Use It
LGPD is mandatory for legal compliance, avoiding fines up to 2% Brazilian revenue (R$50M cap). It mitigates risks from breaches, builds stakeholder trust, enables market access in Brazil's digital economy, and provides competitive edges through privacy-by-design.
Implementation Overview
Phased, risk-based: data mapping, DPO appointment, policies, technical controls, training. Applies to all sizes/industries processing Brazilian data globally. No certification; focuses on self-assessments, ANPD audits. (178 words)
Key Differences
| Aspect | APPI | LGPD |
|---|---|---|
| Scope | Personal data handling, consent, security, rights | Personal data processing, 10 principles, rights, transfers |
| Industry | All sectors in Japan, extraterritorial for targeting Japan | All sectors targeting Brazil, extraterritorial reach |
| Nature | Mandatory national law, PPC enforcement | Mandatory national law, ANPD enforcement |
| Testing | PPC audits, self-assessments, vendor audits | DPIAs for high-risk, internal audits, ANPD inspections |
| Penalties | ¥100M fines, 1-2yr imprisonment, PPC orders | 2% Brazil revenue (R$50M cap), suspensions, ANPD sanctions |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about APPI and LGPD
APPI FAQ
LGPD FAQ
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