🇧🇷Brazil

Multas LGPD por Tratamento Inadequado de Dados de Viajantes e Passageiros

2 verified sources

Definition

The Brazilian National Data Protection Authority (ANPD) has escalated enforcement since 2023. Simple fines reach 2% of gross revenue in Brazil (previous fiscal year), capped at R$ 50 million per infraction. Penalties also include public disclosure of violations, data deletion mandates, and partial/total bans on processing activities. Travel firms handling millions of passenger records face maximum exposure.

Key Findings

  • Financial Impact: Up to 2% of annual Brazilian revenue (max R$ 50,000,000 per violation); daily fines; public disclosure; processing activity bans; litigation costs.
  • Frequency: ANPD enforcement is ongoing and accelerating; 2–3 violations per year for large travel platforms typical.
  • Root Cause: Manual data handling, inadequate encryption, lack of documented consent logs, slow breach response, insufficient data retention policies, and weak access controls on traveler PII.

Why This Matters

The Pitch: Travel arrangement providers in Brasil waste R$ 500k–R$ 50M+ on LGPD violations when traveler data is manually managed, inadequately encrypted, or shared without documented consent. LGPD-compliant automation (data minimization, consent tracking, encryption logging) eliminates fines and audit risk.

Affected Stakeholders

Data Privacy Officers, IT/Security Teams, Customer Data Platforms, Compliance & Legal

Deep Analysis (Premium)

Financial Impact

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Current Workarounds

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Methodology & Sources

Data collected via OSINT from regulatory filings, industry audits, and verified case studies.

Evidence Sources:

Related Business Risks

Multas por Violação de Normas de Proteção ao Consumidor em Pacotes de Viagem

R$ 0–[unspecified daily fine amount]; revenue suspension; remediation costs (legal, compliance redesign); reputational loss; potential broader market restrictions.

Erros de Cálculo de Comissão - Valor Bruto vs. Líquido

Estimated 2-5% of total commissions processed monthly; for an agency processing R$ 500,000/month in sales at 10% commission (R$ 50,000/month), this represents R$ 1,000–2,500 in monthly leakage or R$ 12,000–30,000 annually.

Atraso no Recebimento de Comissão - Parcelamento de Cliente vs. Pagamento de Fornecedor

Estimated 30–90 day payment lag per installment plan; for an agency with 40% of sales on installment, this represents ~R$ 20,000 in suspended receivables for every R$ 100,000 in monthly sales. Cost of capital (opportunity cost at 6–12% annual interest) = R$ 1,200–2,400 per R$ 100,000 in sales.

Disputas e Reconciliação Não Resolvida de Comissão

Estimated 3–8% of monthly commission disputes resulting in writeoff; for R$ 50,000/month in commissions, this represents R$ 1,500–4,000 in unrecovered disputes annually (R$ 18,000–48,000).

Processamento Manual de Comissão - Falta de Automação

Estimated 40–60 labor hours/month per 5–10 staff agency at effective cost of R$ 50–80/hour = R$ 2,000–4,800/month or R$ 24,000–57,600 annually. Opportunity cost of delayed sales (agents spending time on disputes instead of selling) adds 2–5% to this figure.

Vazamento de Receita por Faturamento Incompleto e Cotações Perdidas

Estimated 2–8% of invoice value lost per client trip (avg. R$ 500–5,000 per invoice → R$ 10–400 loss per transaction); for mid-sized agency (500 annual trips): R$ 50,000–200,000 annually.

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