How can ManageEngine support LGPD compliance?
With ManageEngine AD360, organizations can begin aligning with LGPD principles through centralized identity governance, multi-factor authentication, continuous monitoring of access to personal data, real-time threat detection, and comprehensive audit trails to support regulatory and audit requirements.
Article 6 General Principles of Personal Data Processing
Organizations must ensure all personal-data processing aligns with LGPD’s ten principles: Purpose, Adequacy, Necessity, Free Access, Data Quality, Transparency, Security, Prevention, Non-discrimination, and Accountability. These principles must guide the entire data lifecycle—from collection to deletion—and serve as the foundation for evaluating and demonstrating compliance.
- Correlated Events Report
- File Integrity Monitoring Summary Report
- UEBA Anomaly Report
- Database Query Access Logs
- DML/DDL Change Monitoring Report
- Log Integrity Verification Report
- Privilege Escalation Attempts Report
- Suspicious Outbound Transfer Report
- Security Control Tampering Report (Firewall/Defender/ETW)
- File Access & Integrity Reports
- Data Classification Evidence
- USB/Email/Web DLP Violations
- Ransomware Detection Logs
Identity & Directory Auditing
- AD Object Modification Report
- User Logon/Logoff Trail
- Permission Change Report
- Group Membership Changes Report
- File Access & Deletion Audit Report
- GPO Change Report
- Stale Account Detection Report
Identity Governance & Administration
- User Attribute Change Reports
- Admin Activity Audit
- Inactive User & Stale Computer Reports
- Privileged Users Review Report
- Bulk Modification Audit Logs
Authentication & Self-Service Security
- MFA Enrollment/Usage Reports
- Password Reset/Unlock Logs
- Context-based Authentication Reports
Articles 17–22 Data subject rights
LGPD grants individuals full control over their personal data, allowing them to access, correct, delete, transfer, or request human review of automated decisions. Organizations must provide clear, timely responses and maintain full traceability of all actions taken on a data subject’s personal data.
Identity Administration & Governance
- User Modification Report
- User Details Report
Directory & File Auditing
- Access Audited File / Folder Report
- AD Object Modification Report
- AD Object Deletion Audit Report
Self-Service & User Accountability
- User Profile Update Report
- Self-Service History / Audit Log
Identity Administration & Data Subject Rights
- Customizable reporting templates to export all PII fields quickly for access requests
- Attribute modification workflows ensuring controlled, auditable data corrections
- Secure deletion workflows supporting permanent account and data removal
- Data export automation producing interoperable formats for data portability
Self-Service & User Accountability
- Self-service profile update portal for secure correction requests
- Consent revocation logging with immutable audit evidence
Directory & File Auditing
- Deletion audit alerts confirming execution of deletion requests
- AD object modification reports with detailed PII change history
- File and folder access auditing to confirm existence of processing
Article 37 Accountability and documentation
Any organization handling personal data must keep written records of what data they process, why they process it, and how. This is especially important when using “legitimate interest” as the legal basis. These records help prove to regulators that the organization is handling data responsibly and transparently.
Administration, Governance & Access Control
- Admin Audit Report
- Help Desk Audit Report
- GPO Reports (All GPOs and Linked Objects)
- User Modification Reports
- User Creation / Deletion Reports
- Group Membership Reports
- Password Policy & Account Policy Reports
- Access Certification Reports
Directory & Identity Auditing
- All AD Change Reports
- User Attribute Change Reports
- Group Membership Change Reports
- Logon / Logoff Audit Reports
- Password Change Reports
- Configuration Change Audit Reports
- Log Clear Reports
File & Resource Access (AD-integrated)
- File Server Access Reports
- File Modification / Deletion Reports
Authentication & Self-Service Security
- Reset Password Audit Report
- Change Password Audit Report
- User Attempts Audit Report
- MFA Usage Audit Report
- MFA Failures Report
Cloud Identity & Collaboration Auditing
- Exchange Online Audit Reports
- Azure AD Modification Reports
- SharePoint & OneDrive File Access / Change Reports
- Teams Activity Reports
Backup & Recovery Accountability
- Backup Audit Trail Report
- Recovery Event Report
- Version History & Restoration Records
- Enable Admin Audit Logging to track all administrative actions
- Enable Workflow with Approval Logs to document request → approval → execution chains
- Implement Access Certification Campaigns for periodic verification of entitlements
- Use Detailed User Modification Tracking to log changes to personal attributes
- Automate Deprovisioning to ensure complete records of account removals
- Maintain GPO Reports to document policy enforcement on systems processing personal data
- Use Delegation Controls for least privilege + traceability of delegated operations
- These are the primary controls for Article 37
- Enable Real-Time AD Auditing for all user, group, and GPO changes
- Track Before/After Attribute Values to maintain evidence of processing
- Enable Logon/Logoff Auditing to prove authenticated session activity
- Audit File Access / File Changes for all servers storing personal data
- Enable Policy & Privilege Change Monitoring to prove governance enforcement
- Enable Log Integrity Monitoring (log cleared, service stopped, tampering)
- Activate Multi-Domain Consolidated Auditing for central accountability across Org
- Enable High-Privilege User Monitoring for privileged operations
- Enable MFA Logs & Password Activity Logs for accountability in identity lifecycle
- Enable Self-Service Audit Trails for profile updates and reset actions
- Enforce Password Policy Controls to prove secure identity processing
- Enable Exchange Online Access Auditing for mailbox data processing
- Enable OneDrive & SharePoint File Access Audits for personal-file processing
- Monitor Azure AD User/Group Changes to maintain cloud-side identity audit trails
- Monitor Teams Activity Logs to track collaboration-related processing
- Enable Backup Audit Trails for all backup operations
- Enable Recovery Logs with who-initiated, what-restored, when
- Maintain Version Histories to prove retention of data processing records
- Enable Attribute-Level Restoration Logs to show precision changes
Article 41 Data Protection Officer (DPO) & Establishment of a Communication Channel
Organizations must appoint a Data Protection Officer (DPO) to act as the main contact for data subjects and the ANPD. The DPO oversees compliance efforts, handles data-subject requests, supports incident response, and ensures transparency. A clear, publicly available communication channel must be provided so individuals can easily exercise their LGPD rights.
- AD Object Modification Report
- User Attribute Change Audit
- Group Membership Changes Report
- Admin Activity Tracking Report
- File Access Audit Reports for PII folders
- Logon/Logoff Trail for DPO & related systems
- GPO / Security Policy Modification Reports
- Admin Action Audit Logs
- User Data Export Logs
- Access Requests / Modification Workflow Logs
- DPO-Specific Administrative Action Logs
- Inactive User Reports (for safeguarding DSR workflows
- MFA Activity Reports for DPO systems
- Password Reset & Account Unlock Logs
- Authentication Logs with Contextual Metadata
Identity Governance & DSR Operations
- Implement DPO-specific RBAC roles enforcing least-privilege access
- Workflow automation for DSR handling (Access, Correction, Deletion)
- Maintain comprehensive audit logs for all identity modifications
- Automated offboarding and stale account cleanup to protect DPO channels
- Delegated administration with approval-based workflows
- Real-time auditing of AD changes relevant to DSR workflows
- Privileged access monitoring to detect unauthorized changes
- Activity tracking of sensitive accounts, including DPO accounts
- File auditing for repositories containing DSR requests or evidentiary data
- MFA-enforced security for DPOs, administrators, and sensitive systems
- Password policy enforcement for accounts linked to privacy operations
- Audit trails for authentication events and profile updates
Article 46 Security measures for processing personal data
Organizations must protect personal data by applying technical and administrative safeguards that ensure confidentiality, integrity, and availability. This includes risk-based security measures such as access control, encryption, continuous monitoring, secure system design, employee training, auditing, and maintaining reliable evidence of all data-processing and security activities.
- Inactive users report
- Stale computers report
- Disabled users report
- Users with expired passwords report
- Access certification report
- Administrator action / audit reports
- MFA usage audit report
- MFA enrollment report
- Password policy enforcement status report
- Failed MFA attempts report
- Sensitive files/folders access report
- NTFS / Exchange permission change report
- GPO / Security policy modification report
- User logon / logoff activity report
- AD object deletion audit report
- User attribute modification report (for PII processing)
- Privileged group membership changes report
- Authentication policy change report
- Backup audit trail
- Restore operation audit report
- Version history and integrity evidence reports
- Real-time AD change auditing (users, groups, computers, OUs, GPOs)
- Monitoring for privilege escalation & risky group membership changes
- GPO and security configuration change monitoring
- Authentication monitoring (logons, failures, lockouts, abnormal behavior)
- User behavior analytics (identity-focused anomalies)
- Log integrity checks (log cleared, service stopped)
- Automated stale account cleanup (inactive users/computers)
- Access certification workflows
- Delegation & approval workflows with full audit trails
- Identity risk assessment for AD & M365
- Context-aware MFA (VPN, endpoints, cloud apps)
- Strong password policy enforcement
- Detection of weak/breached credentials
- Auditing of password resets, unlocks, MFA changes
- Sensitive file access auditing (read/write/delete on PII)
- Real-time file access logging (evidence of processing)
- File modification & deletion auditing
- Permission change auditing
- DLP controls to prevent unauthorized data movement
- Ransomware early detection & automated containment
- Secure, versioned backups for AD, M365, Exchange, SharePoint
- Immutable backup configurations
- Integrity verification
- Detailed restore operation logs (evidence of processing)
Article 48 Breach notification
Organizations must promptly detect, assess, and report any personal data breach that may pose risk or harm. Notifications to the ANPD and affected individuals must clearly describe what data was impacted, the risks involved, actions taken, and provide DPO contact details. Organizations must retain logs, audit trails, and incident evidence to support regulatory investigations and demonstrate transparency.
- User Details Report
- Account Creation / Deletion Report
- Privileged Role Assignments
- Inactive / Stale Account Reports
- Sensitive Files/Folders Access Report
- Failed / Successful Access Attempts Report
- User Logon/Logoff Audit Report
- GPO or Security Policy Modification Report
- AD Object Deletion & Modification Audit
- Privileged Group Membership Change Report
- User Attribute (PII) Modification Report
- Backup Audit Trail (proves backup state at time of breach)
- Restore Operation Evidence (post-incident recovery actions)
- Version History Report (tampering assessment)
- Enforce Context-Based MFA to prevent unauthorized access during breaches
- Enforce Strong Password Policies to reduce credential compromise risk
- Maintain full password/MFA change audit trails for forensic review
- Automate Inactive Account Cleanup (removes breach entry points)
- Use Bulk Attribute Modification with Audit Trails for remediation actions
- Apply Delegation Workflows for controlled incident-response changes
- Maintain Privilege Management & Role-based Access documentation
- Enable Real-time AD Change Auditing for breach indicators
- Monitor Sensitive Data Access (read, write, delete events)
- Audit GPO / Security Policy Modifications (attackers often disable security)
- Enable Privileged Access Monitoring for Domain Admin / Enterprise Admin events
- Track Failed Logons, Account Lockouts, and Lateral Movement patterns
- Detect Log Clearing / Tampering attempts for forensic completeness
- Maintain versioned, tamper-proof backups of AD & M365
- Provide auditable restore operations post-breach
- Support rollback to pre-incident state with evidence logs
Article 49 Secure system design
Article 49 requires that any system used to process personal data must be designed and operated according to security requirements, good practices, governance principles, and relevant regulatory standards. This means organizations must embed security from the beginning (“security by design”), maintain continuous protection (“security by default”), and ensure that every system handling personal data follows robust, verifiable, and auditable security practices.
- GPO Modification Report
- Security Policy Change Report
- AD Object Modification Report
- Logon / Logoff Activity Report
- Privileged Group Membership Change Report
- GPO / OU / Permission Change Reports
- Delegated Admin Activity Report
- Inactive Accounts Report
- Users with Elevated Permissions Report
- MFA Usage Audit Report
- Password Policy Compliance Report
- Exchange / SharePoint / OneDrive Permission Change Reports
- Azure AD User / Role Modification Reports
- Backup Integrity Reports
- Restoration Activity Reports
- Backup Policy Change Report
- Identity Risk Assessment to identify misconfigurations and insecure identity setups
- Role-Based Access & Delegation to enforce secure access governance and system segmentation
- Automated User Lifecycle Management to remove orphaned or stale accounts that weaken system design security
- GPO and Permission Management enabling strong baseline configurations aligned with secure architecture
- Real-time auditing of all configuration, GPO, and system changes to detect tampering
- Privileged user activity monitoring to enforce governance and prevent unauthorized modifications
- File server auditing to ensure data integrity and detect unauthorized access
- ML-based anomaly detection to identify deviations from secure operational patterns
- Enforce strong authentication (MFA, conditional access) to ensure resilient system design
- Password policy enforcement to prevent weak credential use
- Context-based authentication aligning with governance principles
- Monitoring of cloud system changes (Azure AD, Exchange, SharePoint, Teams)
- Audit trails for permissions and role changes supporting governance and good practices
- Data access insights to validate proper system segmentation and data minimization
- Backup integrity enforcement to ensure system resilience
- Multi-point-in-time recovery to restore secure system states
- Audit trails for backup & restore events supporting governance documentation
Article 50 Good practices and governance
Article 50 requires organizations to maintain a formal and continually updated privacy governance framework. This includes documented policies, security standards, risk-based controls, complaint handling, internal supervision, and training. Governance must reflect the nature and sensitivity of processed data and must demonstrate transparency and accountability to data subjects and the ANPD.
- Azure AD Role & Permission Change Reports
- Exchange/SharePoint/OneDrive Access & Sharing Reports
- Teams Activity & Change Logs
- Backup Integrity Reports
- Backup Policy Change Reports
- Restore Activity & Verification Logs
- Implement Role-Based Access Control (RBAC) and administrative delegation aligned with governance rules
- Automate user lifecycle workflows to maintain a clean, controlled identity environment
- Maintain auditable approval workflows for any access or attribute modification
- Perform periodic access certifications for continuous governance compliance
- Enforce real-time auditing of all configuration, identity, and policy changes
- Monitor privileged user behavior and enforce segregation-of-duties governance
- Maintain tamper-evident logs for all AD governance activities
- Use ML-based anomaly detection to identify governance violations or insider misuse
- Enforce strong authentication governance through MFA, conditional access, and password rules
- Provide auditable self-service changes for user attributes, ensuring traceability
- Enforce context-based authentication policies that reflect governance requirements
- Monitor cloud identity governance, including Azure AD role changes
- Audit permission changes across Exchange, SharePoint, OneDrive, and Teams
- Provide visibility on data sharing, supporting governance transparency
- Enforce backup governance, including retention rules and secure storage
- Maintain immutable backup logs to demonstrate compliance
- Provide incident response restoration plans aligned with governance requirements
Disclaimer: The information provided on this page is for general knowledge and awareness purposes only. It is not intended to serve as professional, legal, or regulatory advice. Compliance with LGPD depends on your organization’s specific environment, processes, and risk profile.
To accurately assess your compliance posture, we strongly recommend engaging a qualified consultant, compliance agency, or referring directly to the official LGPD documentation and guidelines.
