Recently, on 14 June 2023, the Brazilian National Data Protection Authority (“ANPD” or “Brazilian DPA”) made available to the public a template of a Record of Processing Activities (“ROPA”) specifically designed for small processing agents.
The template’s publishing by the Brazilian DPA was a requirement provided by article 9 of the Resolution CD/ANPD n. 02/2021, which established the applicable rules to the small processing agents, as per the same Resolution.
According to the regulation, these agents would be able to comply with their data processing record obligations in a simplified manner with a ROPA’s template that would be established by the ANPD, which just occurred.
The template provides the categories considered as a priority by the Brazilian DPA as well as guidance regarding its filling, is available in Portuguese in a .pdf version and in an Excel version.
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