The ANPD, the authority responsible for overseeing compliance with the LGPD, is taking input for the preparation of a model for registration of personal data processing operations by small data processing agents. Interested parties may contribute until December 4th of this year.
The register of personal data processing operations, popularized as "RoPA" (Record of Processing Activites) is one of the obligations imposed by the LGPD on all companies that collect or use personal data. The RoPA contains the map of personal data flows in the company and can give an overview of the data inventory, protections, sharing and risks, allowing a privacy governance program to be implemented, compliance with rights guaranteed by the LGPD, among other relevant points.
Small-sized agents, defined by the ANPD as startups or legal entities with lower revenues that do not make use of personal data of greater impact, are subject to different treatment by the LGPD and will have a simplified model of RoPA to be followed in an attempt to unburden the activities of these companies and foster their adherence to these legal obligations of data protection. For other companies, this model can serve as a parameter for the adoption of their own more detailed records, while the ANPD still does not regulate the matter.
If you would like to find out whether you qualify as an ATTP, or are interested in taking part in grant-making, please contact our specialist Data Protection and Privacy team.
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