Your Salesforce Org Has Three LGPD Exposure Points
of Brazil revenue per violation, up to R$50M maximum per LGPD Article 52
Your org likely stores Brazilian personal data across Contacts, Leads, Accounts, and custom objects. You have no automated deletion schedule. When the ANPD investigates, inspectors ask for documentation of your retention policies and deletion runs. If you cannot produce audit logs for systematic data minimization, the burden of proof shifts against you. Fines scale with your revenue, and the ANPD has signaled it is enforcing actively.
LGPD deadline to fulfill titular access and deletion requests
LGPD gives your Brazilian data subjects 15 days to receive a response to access or deletion requests. That is half the GDPR window. Fulfilling a deletion request in Salesforce manually means tracking down related records across multiple objects, running SOQL queries, coordinating approvals, and documenting the outcome. For any org with thousands of Brazilian records, manual fulfillment is infeasible within 15 days.
breach notification deadline under LGPD Article 48
Your Salesforce sandbox refreshes copy production data, including Brazilian personal data, into environments accessible to developers, contractors, and QA testers. These are the least-controlled environments in your Salesforce footprint. A breach originating in a sandbox still triggers LGPD's 72-hour notification requirement. The ANPD treats sandbox breaches the same as production breaches when the underlying data is real.
Three LGPD Obligations Every Salesforce Org Must Meet
Brazil's Lei Geral de Proteção de Dados creates specific obligations for organizations processing personal data of Brazilian residents. Three requirements expose every unprotected Salesforce implementation:
LGPD Article 6(III)
Data Minimization and 2-Year Deletion Windows
LGPD requires organizations to collect only what is necessary and delete personal data when its purpose is fulfilled. Inactive Brazilian records must be purged within 2 years. Salesforce retains everything by default with no automated enforcement of retention limits.
Data Retention ManagerLGPD Article 18
15-Day Titular Rights Fulfillment
Your Brazilian data subjects have the right to access, correct, and erase their personal data. Your team must respond within 15 days. Deletion must cascade across related records without breaking data integrity. Manual SOQL queries and CSV exports cannot reliably meet this deadline at scale.
Privacy Rights AutomationLGPD Article 46
Sandbox and Development Environment Security
LGPD requires appropriate technical security measures proportional to data sensitivity. Your developers and contractors accessing Salesforce sandboxes containing real Brazilian personal data are an unaddressed exposure. Masking is required; encryption alone does not satisfy this obligation when authorized users can see the data.
DataMaskerArticle 52
LGPD administrative sanctions
The Autoridade Nacional de Proteção de Dados applies these sanctions after an administrative procedure, following the dosimetry rules in ANPD Resolution CD/ANPD nº 4/2023.
| Sanction | Article | Limit |
|---|---|---|
| Simple fine | Art. 52(II) | Up to 2% of revenue in Brazil for the prior year, capped at R$50 million per infraction |
| Daily fine | Art. 52(III) | Subject to the same R$50 million cap |
| Warning, with a deadline for corrective measures | Art. 52(I) | — |
| Publicising the infraction | Art. 52(IV) | — |
| Blocking or deletion of the personal data involved | Art. 52(V), (VI) | — |
| Partial suspension of the database, or of the processing activity | Art. 52(X), (XI) | Up to 6 months, extendable once |
Source: Lei nº 13.709/2018 (LGPD), Article 52. Figures last checked . R$50 million is roughly US$9 million at recent exchange rates.
Three Products. Three LGPD Requirements. One Platform.
Article 6(III): Data Minimization
Data Retention ManagerEnforce 2-Year Retention Windows for Brazilian Records
Data Retention Manager implements LGPD minimization requirements as metadata-driven policies. Configure deletion schedules by object type, country, and data category. Inactive Brazilian Leads, Contacts, and custom records are flagged and deleted when their retention period expires. Deletion audit logs document every run for ANPD documentation purposes. Handles multi-jurisdiction complexity when your org spans LGPD, GDPR, and CCPA simultaneously.
Article 18: Titular Rights
Privacy Rights AutomationFulfill 15-Day Deletion and Access Requests
Privacy Rights Automation handles LGPD titular rights requests end-to-end. From request intake through cascade deletion across all related Salesforce objects, with a complete audit trail for ANPD documentation. Identity verification built in. Average request handled in one click instead of days of manual SOQL work. Covers access, correction, deletion, and portability as required under LGPD Article 18.
Article 46: Technical Security Measures
DataMaskerMask Brazilian PII on Every Sandbox Refresh
DataMasker masks all personal data from Brazilian records automatically on every sandbox refresh. Names, CPF numbers, addresses, and contact data are replaced with realistic but fake values. Developers and contractors access realistic sandboxes without touching real titular data. Email automations are suppressed to prevent unintended customer contact. Complete audit trail for ANPD documentation. 5M records per hour throughput.
Key Takeaways
ANPD enforcement framework mirrors GDPR structure, up to 2% of Brazil revenue in fines per violation
Titular data rights automated: access, correction, deletion, and portability covered in one click
15-day DSAR window met with cascade deletion across all related Salesforce objects and audit log
LGPD applies to any org processing Brazilian personal data regardless of where your org is hosted
Data minimization automated: retention policies delete obsolete titular records on schedule
Single installation covers LGPD, GDPR, and CCPA simultaneously, multinational compliance unified
Frequently Asked Questions
Yes. LGPD applies to any organization processing personal data of Brazilian residents, regardless of where your company is located or where your Salesforce org is hosted. If your Contacts, Accounts, or Opportunities include Brazil-based records, LGPD applies. The ANPD's enforcement has been active since 2020. Compliance is not optional.
Both require data minimization, consent, and deletion rights. But LGPD has a 15-day DSAR response window (vs. 30 days for GDPR), a 2-year retention limit for unnecessary data, and R$50M maximum fines per violation. LGPD enforcement is emerging; GDPR enforcement is established and aggressive. Both require the same technical automation in Salesforce.
ANPD can issue warnings, block processing, order data deletion, or impose fines up to R$50M per violation. They can also require mandatory audits and corrections. Unlike GDPR (which has years of enforcement precedent), ANPD is still establishing enforcement patterns. But early actions show they are serious about security, consent, and retention.
Data Retention Manager: 2 to 3 weeks. Privacy Rights Automation: 3 to 4 weeks. DataMasker: 3 weeks. These are clicks-not-code implementations. You don't need Apex developers. Cloud Compliance guides you through the configuration. Implementation is provided over Zoom. We never need direct access to your data.
LGPD Article 6(III) establishes data minimization as a foundational principle: organizations must limit personal data collection and retention to what is strictly necessary. Data Retention Manager enforces this by automatically deleting or anonymizing Salesforce records that exceed your configured retention period. You set the retention rule once, for example, delete inactive Leads older than 24 months, and the manager runs on schedule. This reduces both your LGPD exposure and your Salesforce storage costs simultaneously. Deletion audit logs are maintained for every run, providing evidence of compliance if the ANPD requests documentation.
Yes. LGPD Article 3 has broad territorial scope: it applies to any processing of personal data collected in Brazil or used to offer goods or services to individuals in Brazil, regardless of where the processing organization is located. If your Salesforce org contains records for Brazilian customers, employees, or prospects, LGPD applies to how you process that data, including how long you retain it, whether you respond to titulares' rights requests, and whether you obtain valid consent for marketing. Cloud Compliance supports multi-regulation enforcement from a single org installation.
Related Compliance Solutions
DataMasker: Sandbox PII Protection
Automatic sandbox masking on every refresh. Brazilian personal data never reaches developer environments.
Privacy Rights Automation: Titular Rights
Fulfill LGPD deletion and access requests within 15 days, with complete audit trails.
Data Retention Manager: Minimization Policies
Automated retention schedules per object. Inactive Brazilian records deleted on schedule.
GDPR Compliance for Salesforce
LGPD mirrors GDPR closely. See how Cloud Compliance handles both from a single installation.