LGPD
Brazil's comprehensive federal law for personal data protection
MAS TRM
Singapore guidelines for financial technology risk management.
Quick Verdict
LGPD mandates data protection for Brazilian residents with fines up to 2% revenue, while MAS TRM provides supervisory guidelines for Singapore FIs' technology risks. Companies adopt LGPD for compliance in Brazil's market; MAS TRM for cyber resilience and regulatory scrutiny avoidance.
LGPD
Lei Geral de Proteção de Dados Pessoais (Law No. 13.709/2018)
Key Features
- Extraterritorial scope targets Brazilian residents' data worldwide
- Mandates 10 core principles beyond GDPR's seven
- Fines up to 2% Brazilian revenue capped R$50M
- Requires controller-appointed Data Protection Officer
- Enforces 10 legal bases including credit protection
MAS TRM
MAS Technology Risk Management Guidelines
Key Features
- Board and senior management accountability
- Proportionality based on risk and criticality
- Third-party risk management integration
- Cyber resilience via defence-in-depth
- Annual penetration testing for internet-facing systems
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 comprehensive federal regulation for personal data protection. Enacted in 2018 and fully enforced since 2021, it safeguards privacy rights with extraterritorial scope applying to any processing targeting Brazilian residents. Its risk-based approach emphasizes accountability, minimization, and data subject rights, enforced by the ANPD.
Key Components
- **10 core principlespurpose limitation, necessity, transparency, security, prevention, non-discrimination, accountability.
- 10 legal bases for processing (e.g., consent, legitimate interests, credit protection).
- **Data subject rightsaccess, correction, deletion, portability, objection to automated decisions.
- **Governancemandatory DPO for controllers, DPIAs for high-risk activities, RoPAs. Compliance via graduated sanctions up to 2% Brazilian revenue (R$50M cap).
Why Organizations Use It
LGPD compliance mitigates fines, operational disruptions, and reputational harm while building trust. It enables market access in Brazil's digital economy, leverages anonymization exemptions for innovation, and aligns with GDPR for multinationals. Strategic benefits include efficiency from data mapping and competitive differentiation.
Implementation Overview
**Phased, risk-based methodologygovernance setup, data mapping/RoPAs, policies, technical controls (encryption, access), DSR/incident processes, vendor DPAs with SCCs (mandatory by 2025). Applies to all sizes/industries processing Brazilian data; ANPD audits enforce, no certification but records/DPIAs required.
MAS TRM Details
What It Is
MAS Technology Risk Management (TRM) Guidelines (January 2021) are supervisory guidelines issued by Singapore's Monetary Authority of Singapore (MAS) for financial institutions. They provide a principles-based framework focused on managing technology and cyber risks to ensure confidentiality, integrity, and availability (CIA) of systems and data. The approach emphasizes proportionality based on risk profile, complexity, and criticality.
Key Components
- Covers 15 sections including governance, risk frameworks, secure development, IT operations, resilience, access controls, cryptography, cyber operations, assessments, and audit.
- Synthesizes 12 core principles like board accountability, asset management, third-party oversight, and defence-in-depth.
- No fixed controls; relies on outcomes-based compliance with independent assurance.
Why Organizations Use It
- Mandatory for MAS-supervised FIs to demonstrate robust practices during supervision.
- Mitigates cyber threats, enhances resilience, and builds customer trust.
- Enables digital innovation while avoiding fines and enforcement actions.
Implementation Overview
- Phased: governance setup, asset inventory, risk assessment, control deployment, testing.
- Targets banks, insurers, fintechs in Singapore; scalable by size.
- Requires board-approved strategies, audits; no formal certification.
Key Differences
| Aspect | LGPD | MAS TRM |
|---|---|---|
| Scope | Personal data protection, rights, transfers | Technology/cyber risk governance, resilience |
| Industry | All sectors, Brazil-focused, extraterritorial | Financial institutions, Singapore-regulated |
| Nature | Mandatory law with ANPD enforcement | Supervisory guidelines, proportionate implementation |
| Testing | DPIAs for high-risk processing | Annual PT, vulnerability scans, DR tests |
| Penalties | 2% Brazilian revenue fines, up to R$50M | Supervisory actions, fines, license conditions |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about LGPD and MAS TRM
LGPD FAQ
MAS TRM FAQ
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