Recently, the Brazilian National Data Protection Authority (“ANPD” or “Brazilian DPA”) imposed a preventive measure against Tools for Humanity – TFH, suspending the offer of financial incentives for iris collection.
TFH had been collecting iris biometric data from data subjects interested in obtaining a unique global identifier, offering cryptocurrency payments in return—an initiative widely reported in the media over the past few weeks.
The Brazilian DPA highlighted that a supervisory procedure was already started in November 2024 to assess TFH’s data processing activities. The ANPD determined that offering financial incentives could undermine the data subjects’ free consent by interfering with their autonomy, a concern increased by the fact that consent could not be revoked in this case.
Additionally, the ANPD also ordered TFH to disclose the identity of its Data Protection Officer in its Privacy Policy, in compliance with the obligations set forth in the LGPD and in the Resolution for DPOs, which we analyze in this newsletter.
Our team is at your disposal for further clarifications, as well as to provide assistance with the procedures for fulfilling LGPD and/or ANPD regulatory obligations.
Gustavo Flausino Coelho – gustavo@bastilhocoelho.com.br Fernando Naegele – fernando@bastilhocoelho.com.br