LGPD and document management: 7 practices to reduce risk

Contracts, onboarding forms, proofs of address, ID documents, medical reports: much of the personal data a company processes lives inside documents. That is why compliance with Brazil’s General Data Protection Law (LGPD, Law 13.709/2018) necessarily involves how those documents are received, stored, accessed and disposed of.

Here are seven practices that reduce risk in concrete ways.

1. Know which documents you have — and why

You cannot protect what you don’t know. Inventory document types by department, identifying which personal data each contains, the purpose of processing and the applicable legal basis (performance of a contract, legal obligation, legitimate interest, consent, etc.). This mapping also feeds the record of processing activities required by article 37 of the LGPD.

2. Collect only what is necessary

The necessity principle limits processing to the minimum required for the purpose. Review forms and checklists: many companies request copies of documents “just in case” that are never used and only increase exposure in an incident.

3. Control who accesses each document

Shared folders open to the whole company are one of the most common sources of leaks. Adopt role-based access control under the least-privilege principle, strong authentication and periodic permission reviews — especially when employees change roles or leave.

4. Record processing operations

Who viewed, downloaded, changed or shared a document? A reliable audit trail helps investigate incidents, demonstrate compliance to Brazil’s National Data Protection Authority (ANPD) and respond to data subjects with confidence.

5. Define retention periods and dispose securely

The LGPD requires data to be deleted once processing ends, except in cases such as compliance with legal obligations or the regular exercise of rights. A retention schedule stating how long each document type must be kept avoids two opposite mistakes: discarding before the legal deadline and keeping indefinitely data that should no longer exist. Disposal must be secure and documented.

6. Handle sensitive data with extra care

Health, biometric, racial or ethnic origin data, among others, are sensitive personal data (art. 5, II) with more restrictive legal bases (art. 11). Medical certificates, health records and selfies used for biometric verification deserve segregation, encryption and even tighter access.

7. Choose your processors carefully

When you outsource digitization, storage, signatures or document BPO, the vendor becomes a processor of the data. Set out in the contract the processing instructions, security controls, confidentiality, audit rights, incident notification and the return or deletion of data at the end of the relationship. Also check where data is stored and whether there are international transfers.

What if something goes wrong?

Have an incident response plan. ANPD regulations set deadlines and minimum content for reporting incidents that may cause relevant risk or harm to data subjects. Knowing in advance who decides, who investigates and who communicates makes all the difference in the first hours.

LGPD compliance is not a project with an end date: it is a set of habits built into the company’s document routine.

Where to start

Start with the areas that handle the most personal data — usually HR, sales and customer service. A quick assessment of their document flows typically reveals immediate security and efficiency gains, such as eliminating unnecessary copies and centralizing documents in a repository with access control.

This content is informational and does not replace advice from your DPO or legal counsel.