LGPD
Brazil's comprehensive personal data protection regulation
GDPR UK
UK regulation for personal data protection and privacy.
Quick Verdict
LGPD governs Brazilian residents' data with 10 principles and ANPD enforcement, while GDPR UK protects UK data via 7 principles and ICO oversight. Multinationals adopt both for compliance in Brazil and UK markets, avoiding hefty fines and building trust.
LGPD
Lei Geral de Proteção de Dados Pessoais (Law 13.709/2018)
Key Features
- Applies extraterritorially to processing targeting Brazilian residents
- Mandates 10 principles including prevention and non-discrimination
- Imposes fines up to 2% Brazilian revenue per infraction
- Requires controllers to appoint Data Protection Officer
- Mandates ANPD-approved SCCs for cross-border transfers
GDPR UK
UK General Data Protection Regulation
Key Features
- Accountability principle requiring demonstrable compliance
- Seven core data processing principles
- Comprehensive data subject rights enforcement
- 72-hour ICO breach notification obligation
- Risk-based DPIAs and prior consultations
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
LGPD Details
What It Is
Lei Geral de Proteção de Dados Pessoais (LGPD), Law No. 13.709/2018, is Brazil's landmark data protection regulation enacted in 2018. It establishes a comprehensive framework for personal data processing, with extraterritorial scope covering any operations targeting Brazilian residents. Modeled on GDPR but adapted to Brazilian rights, it uses a risk-based approach guided by 10 core principles like purpose limitation, necessity, and accountability.
Key Components
- 10 principles (e.g., transparency, security, prevention, non-discrimination).
- Data subject rights (access, correction, deletion, portability, anonymization, objection to automation).
- 10 legal bases for processing (consent, contracts, legitimate interests, etc.), stricter for sensitive data.
- **Governance toolsmandatory DPO for controllers, Records of Processing Activities (RoPAs), DPIAs for high-risk activities.
- Enforcement via ANPD with graduated sanctions.
Why Organizations Use It
Mandatory compliance avoids fines up to 2% Brazilian revenue (R$50M cap), operational halts, and reputational harm. Builds stakeholder trust, enables market access in Brazil's digital economy, mitigates breach risks, and supports innovation via anonymization exemptions.
Implementation Overview
Phased risk-based methodology: governance/DPO appointment, data mapping/RoPAs, policies/contracts, technical controls (encryption, access), DSR/incident processes, monitoring/audits. Applies universally—no size exemptions—for public/private entities processing personal data. ANPD enforces via audits/sanctions; no formal certification.
GDPR UK Details
What It Is
UK GDPR (UK General Data Protection Regulation) is the UK's post-Brexit data protection law, adapting EU GDPR via the Data Protection Act 2018. It is a binding regulation enforcing personal data processing for controllers and processors in or targeting the UK. Its risk-based, accountability-focused approach mandates demonstrable compliance with principles like lawfulness and security.
Key Components
- **Seven core principleslawfulness, purpose limitation, minimisation, accuracy, storage limitation, integrity/confidentiality, accountability.
- **Data subject rightsaccess, rectification, erasure, portability, objection.
- **Obligationsrecords of processing (RoPA), DPIAs, processor contracts, breach notifications.
- No formal certification; compliance via ICO enforcement, fines up to 4% global turnover.
Why Organizations Use It
- Legal mandate for UK data handlers; extraterritorial scope.
- Mitigates fines (£17.5M max), reputational damage, civil claims.
- Builds trust, enables secure data use, supports cross-border operations.
Implementation Overview
Phased: data mapping (RoPA), policies, training, DPIAs, vendor contracts. Applies to all sizes handling UK personal data; ICO audits enforce.
Key Differences
| Aspect | LGPD | GDPR UK |
|---|---|---|
| Scope | Personal data of Brazilian residents, extraterritorial | Personal data of UK individuals, extraterritorial |
| Industry | All sectors, Brazil-focused, no size exemption | All sectors, UK-focused, public/private |
| Nature | Mandatory Brazilian law, ANPD enforcement | Mandatory UK law, ICO enforcement |
| Testing | DPIAs for high-risk, ANPD audits | DPIAs mandatory high-risk, ICO audits |
| Penalties | 2% Brazilian revenue, R$50M cap | 4% global turnover, £17.5M max |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about LGPD and GDPR UK
LGPD FAQ
GDPR UK FAQ
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