The National Data Protection Agency has updated the Guidance for the Definition of Data Processing Agents and Data Controllers, in order to clarify doubts about who the data processing agents are and what their responsibilities are.
Version 2.0 of the Guide updates the original version to adjust, among other things, clarifications on the definitions and examples of who can perform the functions of controller, operator, and manager, and what their responsibilities are; to relate the discussion to Resolution CD/ANPD No. 2, of January 27, 2022, which approves the Regulation for the Application of the LGPD for Small-Scale Data Processing Agents; as well as to bring concepts present in more complex chains, such as the sub-operator, illustrating the cases and relating the applications of this concept.