On April 26, 2022, the National Data Protection Authority (“ANPD”) launched version 2.0 of the “Guide for Definitions of Agents for the Processing of Personal Data and the Data Protection Officer”. This update was made based on contributions by civil society from the maturing of the theme and the compatibility of the guide with other standards established by ANPD.

The new version seeks to clarify important concepts that had been generating doubts in the Brazilian General Data Protection Law (LGPD), especially about the agents of treatment, explaining who can perform the function of controller, processor and DPO, their legal definitions, the respective liability regimes, as well as concrete cases that exemplify the explanations.

Moreover, version 2.0 clarifies the attributions of the Data Protection Officer and the needlessness of registering his identity with the ANPD, relating its contents to the application of the LGPD to Small-Sized Treatment Agents.

In addition, the new version of the guide conceptualizes and exemplifies more complex chains, such as the sub-processors, with practical day-to-day examples.

Currently, the ANPD has 5 orientative guidelines that aim to raise awareness and educate on issues that envolve the protection of personal data, aiming to bring greater legal certainty to data subjects and agents, corroborating the application of best practices in personal data protection.

Link to the Guide for Definitions of Agents for the Processing of Personal Data and the Data Protection Officer:


For more information, please contact Saud Advogados.