Guidance for definitions of Personal Data Processing Agents and Data Protection Officers

On May 28, 2021, the Brazilian Data Protection Authority (ANPD) released guidance on controllers and processors’ functions and responsibilities, as well as on the data protection officer role. ANPD’s guidance also covered an explanation of joint controllership and subprocessors, including potential consequences. The topic is paramount for the understanding of any data protection and privacy regulation, mainly in light of the controllers and processors’ allocation of liabilities. This Legal Update provides further detail.