Standards Comparison

    LGPD

    Mandatory
    2020

    Brazil's comprehensive federal law for personal data protection

    VS

    MAS TRM

    Mandatory
    2021

    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.

    Data Privacy

    LGPD

    Lei Geral de Proteção de Dados Pessoais (Law No. 13.709/2018)

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    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
    Technology Risk Management

    MAS TRM

    MAS Technology Risk Management Guidelines

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    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

    Scope

    LGPD
    Personal data protection, rights, transfers
    MAS TRM
    Technology/cyber risk governance, resilience

    Industry

    LGPD
    All sectors, Brazil-focused, extraterritorial
    MAS TRM
    Financial institutions, Singapore-regulated

    Nature

    LGPD
    Mandatory law with ANPD enforcement
    MAS TRM
    Supervisory guidelines, proportionate implementation

    Testing

    LGPD
    DPIAs for high-risk processing
    MAS TRM
    Annual PT, vulnerability scans, DR tests

    Penalties

    LGPD
    2% Brazilian revenue fines, up to R$50M
    MAS TRM
    Supervisory actions, fines, license conditions

    Frequently Asked Questions

    Common questions about LGPD and MAS TRM

    LGPD FAQ

    MAS TRM FAQ

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