The LGPD signals the need to record personal data processing operations for controllers and operators, hereinafter referred to as “processing activities”, also known by the acronym ROPA. It is safe to say that the genesis of data protection management lies in the records of such activities. These records contain the essential elements that make it possible to adapt an organization, a process or an activity to the LGPD.
In fact, there is no way to
Adapt or mobile phone number data updated 2025 adequate without taking into account the support activities and end activities. Business processes and corporate processes contain the activities of processing personal data. And following this rationale, considering the beginning through the analysis of the value chain is to aim for assertiveness.
However, each context is unique
There is not always maturity for a value chain, a structured process description or, perhaps, a defined organizational chart. And yet, from the perspective of the LGPD, there is beauty in chaos. A good LGPD compliance project allows us to open the doors to identify, analyze, question, review and restructure. A compliance project must culminate in a good program. And a good, well-managed program is always focused on personal data processing activities.
An organization is alive
Undergoes changes, incorporates new processes, changes existing ones and stops performing others. And why invest in an adtech? there are frameworks and methodologies, rigid, complex or bureaucratic models that prevent a non-specialist from seeing the value contained in each of the steps in the recording of treatment activities are not appropriate. In the first wave of the journey to adequacy, the basics well done work and produce results.
I am not in favor of ready-made recipes
Defined packages when it comes to LGPD, but I am extremely in favor of a strategic vision based on knowledge – tacit or explicit. Pinpointing the activities of processing personal data in business processes or corporate processes to proceed with registrations, although it is a simple act, requires listening, curiosity, interest and the establishment of a relationship of trust between the parties. Mapping “what is it > what purpose > who does it > how it is done > which data elements are processed > which systems and/or supports > how it is stored/sent/shared > to whom it is sent or shared” points to developments that allow reconciling minimization, risk analysis, assignment of a legal basis, inventory and information security. Maturity and the next steps are natural consequences of a secure program.
Treating compliance as a project in itself is a mistake. Not developing a program that encompasses all functional areas is a mistake. Not uae phone number records is a mistake. Paying attention to internal movements within the organization is a mistake. But we also learn from our mistakes, and as good students, we must always be vigilant.