LGPD
Brazil's comprehensive regulation for personal data protection
UAE PDPL
UAE federal regulation for personal data protection
Quick Verdict
LGPD mandates comprehensive data protection for Brazilian residents with 10 principles and ANPD enforcement, while UAE PDPL regulates onshore private sector processing with risk-based DPIAs and Data Office oversight. Companies adopt them for legal compliance, fines avoidance, and trust-building in regional markets.
LGPD
Lei Geral de Proteção de Dados Pessoais (Law 13.709/2018)
Key Features
- Extraterritorial scope targets Brazilian residents worldwide
- 10 core principles expand GDPR with prevention
- Fines up to 2% Brazilian revenue capped R$50M
- Mandatory DPO appointment for controllers publicly disclosed
- SCCs required for cross-border transfers by 2025
UAE PDPL
Federal Decree-Law No. 45/2021 Personal Data Protection
Key Features
- Extraterritorial scope for UAE residents' data
- Mandatory Records of Processing Activities (RoPA)
- Risk-based DPO and DPIA requirements
- GDPR-aligned data subject rights
- Breach notification to UAE Data Office
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 data protection regulation. It governs personal data processing with extraterritorial scope targeting Brazilian residents, emphasizing privacy as a fundamental right. Adopts a risk-based approach with 10 principles like purpose limitation and accountability.
Key Components
- **10 core principlesPurpose limitation, necessity, transparency, security, prevention, non-discrimination, accountability.
- **Data subject rightsAccess, correction, deletion, portability, objection to automated decisions.
- **Legal bases10 options including consent, legitimate interests, contracts.
- **GovernanceMandatory DPO for controllers, DPIAs for high-risk, enforced by ANPD with graduated sanctions up to 2% revenue (R$50M cap).
Why Organizations Use It
Mandatory compliance avoids multimillion fines, operational halts. Builds trust, enables market access in Brazil's digital economy, reduces breach risks, supports AI innovation via anonymization exemptions.
Implementation Overview
Phased: governance/DPO appointment, data mapping/RoPA, policies, technical controls, DSR/incident processes, vendor/SCC management. Applies to all sizes/sectors processing Brazilian data; ANPD audits enforce, no certification but records/DPIAs required.
UAE PDPL Details
What It Is
UAE PDPL (Federal Decree-Law No. 45 of 2021 Concerning the Protection of Personal Data) is a comprehensive federal regulation establishing UAE's first economy-wide personal data framework. Effective January 2022, it governs processing of personal data onshore, with extraterritorial reach to foreign entities targeting UAE residents. It adopts a risk-based approach emphasizing fairness, transparency, and accountability.
Key Components
- Core principles: lawfulness, purpose limitation, minimization, accuracy, security, storage limitation.
- Obligations: Records of Processing Activities (RoPA), DPO for high-risk, DPIAs, breach notification.
- Data subject rights: access, portability, correction, erasure, objection.
- No fixed control count; compliance via demonstrable measures, aligned to international standards like GDPR.
Why Organizations Use It
- Mandatory for onshore/private sector (excl. free zones, health/banking sectoral laws).
- Mitigates fines, builds trust, enables digital economy participation.
- Enhances cybersecurity, vendor management, cross-border flows.
Implementation Overview
Phased: discovery/gap analysis, remediation, operationalization, monitoring. Applies to all sizes processing UAE data; no certification but RoPA/DPO audits expected. (178 words)
Key Differences
| Aspect | LGPD | UAE PDPL |
|---|---|---|
| Scope | Personal data processing, rights, transfers, high-risk activities | Personal/sensitive data processing, rights, high-risk tech profiling |
| Industry | All sectors, Brazil residents, extraterritorial, all sizes | Private onshore UAE, excludes free zones/health/banking, extraterritorial |
| Nature | Mandatory comprehensive law, ANPD enforcement, graduated sanctions | Mandatory federal law, Data Office enforcement, pending regulations |
| Testing | DPIAs for high-risk/legitimate interests, security measures, audits | Mandatory DPIAs for high-risk tech/sensitive data, security testing |
| Penalties | 2% Brazilian revenue (R$50M cap), suspensions, graduated sanctions | Administrative fines (details pending), sectoral/criminal overlaps |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about LGPD and UAE PDPL
LGPD FAQ
UAE PDPL FAQ
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