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Achieve LGPD compliance with ManageEngine

Brazil’s Lei Geral de Proteção de Dados (LGPD – Law No. 13,709/2018) establishes strict requirements for protecting personal data, mandating strong access controls, data security, incident monitoring, accountability, and auditable processes to prevent unauthorized access, breaches, and misuse of personal information.

Compliance

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

Compliance actions Report and Evidences IAM Controls

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.

  1. Correlated Events Report
  2. File Integrity Monitoring Summary Report
  3. UEBA Anomaly Report
  4. Database Query Access Logs
  5. DML/DDL Change Monitoring Report
  6. Log Integrity Verification Report
  7. Privilege Escalation Attempts Report
  8. Suspicious Outbound Transfer Report
  9. Security Control Tampering Report (Firewall/Defender/ETW)
  10. File Access & Integrity Reports
  11. Data Classification Evidence
  12. USB/Email/Web DLP Violations
  13. Ransomware Detection Logs

Identity & Directory Auditing

  1. AD Object Modification Report
  2. User Logon/Logoff Trail
  3. Permission Change Report
  4. Group Membership Changes Report
  5. File Access & Deletion Audit Report
  6. GPO Change Report
  7. Stale Account Detection Report

Identity Governance & Administration

  1. User Attribute Change Reports
  2. Admin Activity Audit
  3. Inactive User & Stale Computer Reports
  4. Privileged Users Review Report
  5. Bulk Modification Audit Logs

Authentication & Self-Service Security

  1. MFA Enrollment/Usage Reports
  2. Password Reset/Unlock Logs
  3. Context-based Authentication Reports

Articles 17–22 Data subject rights

Compliance actions Report and Evidences IAM Controls

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

  1. User Modification Report
  2. User Details Report

Directory & File Auditing

  1. Access Audited File / Folder Report
  2. AD Object Modification Report
  3. AD Object Deletion Audit Report

Self-Service & User Accountability

  1. User Profile Update Report
  2. Self-Service History / Audit Log

Identity Administration & Data Subject Rights

  1. Customizable reporting templates to export all PII fields quickly for access requests
  2. Attribute modification workflows ensuring controlled, auditable data corrections
  3. Secure deletion workflows supporting permanent account and data removal
  4. Data export automation producing interoperable formats for data portability

Self-Service & User Accountability

  1. Self-service profile update portal for secure correction requests
  2. Consent revocation logging with immutable audit evidence

Directory & File Auditing

  1. Deletion audit alerts confirming execution of deletion requests
  2. AD object modification reports with detailed PII change history
  3. File and folder access auditing to confirm existence of processing

Article 37 Accountability and documentation

Compliance actions Report and Evidences IAM Controls

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

  1. Admin Audit Report
  2. Help Desk Audit Report
  3. GPO Reports (All GPOs and Linked Objects)
  4. User Modification Reports
  5. User Creation / Deletion Reports
  6. Group Membership Reports
  7. Password Policy & Account Policy Reports
  8. Access Certification Reports

Directory & Identity Auditing

  1. All AD Change Reports
  2. User Attribute Change Reports
  3. Group Membership Change Reports
  4. Logon / Logoff Audit Reports
  5. Password Change Reports
  6. Configuration Change Audit Reports
  7. Log Clear Reports

File & Resource Access (AD-integrated)

  1. File Server Access Reports
  2. File Modification / Deletion Reports

Authentication & Self-Service Security

  1. Reset Password Audit Report
  2. Change Password Audit Report
  3. User Attempts Audit Report
  4. MFA Usage Audit Report
  5. MFA Failures Report

Cloud Identity & Collaboration Auditing

  1. Exchange Online Audit Reports
  2. Azure AD Modification Reports
  3. SharePoint & OneDrive File Access / Change Reports
  4. Teams Activity Reports

Backup & Recovery Accountability

  1. Backup Audit Trail Report
  2. Recovery Event Report
  3. Version History & Restoration Records
  1. Enable Admin Audit Logging to track all administrative actions
  2. Enable Workflow with Approval Logs to document request → approval → execution chains
  3. Implement Access Certification Campaigns for periodic verification of entitlements
  4. Use Detailed User Modification Tracking to log changes to personal attributes
  5. Automate Deprovisioning to ensure complete records of account removals
  6. Maintain GPO Reports to document policy enforcement on systems processing personal data
  7. Use Delegation Controls for least privilege + traceability of delegated operations
  8. These are the primary controls for Article 37
  9. Enable Real-Time AD Auditing for all user, group, and GPO changes
  10. Track Before/After Attribute Values to maintain evidence of processing
  11. Enable Logon/Logoff Auditing to prove authenticated session activity
  12. Audit File Access / File Changes for all servers storing personal data
  13. Enable Policy & Privilege Change Monitoring to prove governance enforcement
  14. Enable Log Integrity Monitoring (log cleared, service stopped, tampering)
  15. Activate Multi-Domain Consolidated Auditing for central accountability across Org
  16. Enable High-Privilege User Monitoring for privileged operations
  17. Enable MFA Logs & Password Activity Logs for accountability in identity lifecycle
  18. Enable Self-Service Audit Trails for profile updates and reset actions
  19. Enforce Password Policy Controls to prove secure identity processing
  20. Enable Exchange Online Access Auditing for mailbox data processing
  21. Enable OneDrive & SharePoint File Access Audits for personal-file processing
  22. Monitor Azure AD User/Group Changes to maintain cloud-side identity audit trails
  23. Monitor Teams Activity Logs to track collaboration-related processing
  24. Enable Backup Audit Trails for all backup operations
  25. Enable Recovery Logs with who-initiated, what-restored, when
  26. Maintain Version Histories to prove retention of data processing records
  27. Enable Attribute-Level Restoration Logs to show precision changes

Article 41 Data Protection Officer (DPO) & Establishment of a Communication Channel

Compliance actions Report and Evidences IAM Controls

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.

  1. AD Object Modification Report
  2. User Attribute Change Audit
  3. Group Membership Changes Report
  4. Admin Activity Tracking Report
  5. File Access Audit Reports for PII folders
  6. Logon/Logoff Trail for DPO & related systems
  7. GPO / Security Policy Modification Reports
  8. Admin Action Audit Logs
  9. User Data Export Logs
  10. Access Requests / Modification Workflow Logs
  11. DPO-Specific Administrative Action Logs
  12. Inactive User Reports (for safeguarding DSR workflows
  13. MFA Activity Reports for DPO systems
  14. Password Reset & Account Unlock Logs
  15. Authentication Logs with Contextual Metadata

Identity Governance & DSR Operations

  1. Implement DPO-specific RBAC roles enforcing least-privilege access
  2. Workflow automation for DSR handling (Access, Correction, Deletion)
  3. Maintain comprehensive audit logs for all identity modifications
  4. Automated offboarding and stale account cleanup to protect DPO channels
  5. Delegated administration with approval-based workflows
  6. Real-time auditing of AD changes relevant to DSR workflows
  7. Privileged access monitoring to detect unauthorized changes
  8. Activity tracking of sensitive accounts, including DPO accounts
  9. File auditing for repositories containing DSR requests or evidentiary data
  10. MFA-enforced security for DPOs, administrators, and sensitive systems
  11. Password policy enforcement for accounts linked to privacy operations
  12. Audit trails for authentication events and profile updates

Article 46 Security measures for processing personal data

Compliance actions Report and Evidences IAM Controls

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.

  1. Inactive users report
  2. Stale computers report
  3. Disabled users report
  4. Users with expired passwords report
  5. Access certification report
  6. Administrator action / audit reports
  7. MFA usage audit report
  8. MFA enrollment report
  9. Password policy enforcement status report
  10. Failed MFA attempts report
  11. Sensitive files/folders access report
  12. NTFS / Exchange permission change report
  13. GPO / Security policy modification report
  14. User logon / logoff activity report
  15. AD object deletion audit report
  16. User attribute modification report (for PII processing)
  17. Privileged group membership changes report
  18. Authentication policy change report
  19. Backup audit trail
  20. Restore operation audit report
  21. Version history and integrity evidence reports
  1. Real-time AD change auditing (users, groups, computers, OUs, GPOs)
  2. Monitoring for privilege escalation & risky group membership changes
  3. GPO and security configuration change monitoring
  4. Authentication monitoring (logons, failures, lockouts, abnormal behavior)
  5. User behavior analytics (identity-focused anomalies)
  6. Log integrity checks (log cleared, service stopped)
  7. Automated stale account cleanup (inactive users/computers)
  8. Access certification workflows
  9. Delegation & approval workflows with full audit trails
  10. Identity risk assessment for AD & M365
  11. Context-aware MFA (VPN, endpoints, cloud apps)
  12. Strong password policy enforcement
  13. Detection of weak/breached credentials
  14. Auditing of password resets, unlocks, MFA changes
  15. Sensitive file access auditing (read/write/delete on PII)
  16. Real-time file access logging (evidence of processing)
  17. File modification & deletion auditing
  18. Permission change auditing
  19. DLP controls to prevent unauthorized data movement
  20. Ransomware early detection & automated containment
  21. Secure, versioned backups for AD, M365, Exchange, SharePoint
  22. Immutable backup configurations
  23. Integrity verification
  24. Detailed restore operation logs (evidence of processing)

Article 48 Breach notification

Compliance actions Report and Evidences IAM Controls

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.

  1. User Details Report
  2. Account Creation / Deletion Report
  3. Privileged Role Assignments
  4. Inactive / Stale Account Reports
  5. Sensitive Files/Folders Access Report
  6. Failed / Successful Access Attempts Report
  7. User Logon/Logoff Audit Report
  8. GPO or Security Policy Modification Report
  9. AD Object Deletion & Modification Audit
  10. Privileged Group Membership Change Report
  11. User Attribute (PII) Modification Report
  12. Backup Audit Trail (proves backup state at time of breach)
  13. Restore Operation Evidence (post-incident recovery actions)
  14. Version History Report (tampering assessment)
  1. Enforce Context-Based MFA to prevent unauthorized access during breaches
  2. Enforce Strong Password Policies to reduce credential compromise risk
  3. Maintain full password/MFA change audit trails for forensic review
  4. Automate Inactive Account Cleanup (removes breach entry points)
  5. Use Bulk Attribute Modification with Audit Trails for remediation actions
  6. Apply Delegation Workflows for controlled incident-response changes
  7. Maintain Privilege Management & Role-based Access documentation
  8. Enable Real-time AD Change Auditing for breach indicators
  9. Monitor Sensitive Data Access (read, write, delete events)
  10. Audit GPO / Security Policy Modifications (attackers often disable security)
  11. Enable Privileged Access Monitoring for Domain Admin / Enterprise Admin events
  12. Track Failed Logons, Account Lockouts, and Lateral Movement patterns
  13. Detect Log Clearing / Tampering attempts for forensic completeness
  14. Maintain versioned, tamper-proof backups of AD & M365
  15. Provide auditable restore operations post-breach
  16. Support rollback to pre-incident state with evidence logs

Article 49 Secure system design

Compliance actions Report and Evidences IAM Controls

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.

  1. GPO Modification Report
  2. Security Policy Change Report
  3. AD Object Modification Report
  4. Logon / Logoff Activity Report
  5. Privileged Group Membership Change Report
  6. GPO / OU / Permission Change Reports
  7. Delegated Admin Activity Report
  8. Inactive Accounts Report
  9. Users with Elevated Permissions Report
  10. MFA Usage Audit Report
  11. Password Policy Compliance Report
  12. Exchange / SharePoint / OneDrive Permission Change Reports
  13. Azure AD User / Role Modification Reports
  14. Backup Integrity Reports
  15. Restoration Activity Reports
  16. Backup Policy Change Report
  1. Identity Risk Assessment to identify misconfigurations and insecure identity setups
  2. Role-Based Access & Delegation to enforce secure access governance and system segmentation
  3. Automated User Lifecycle Management to remove orphaned or stale accounts that weaken system design security
  4. GPO and Permission Management enabling strong baseline configurations aligned with secure architecture
  5. Real-time auditing of all configuration, GPO, and system changes to detect tampering
  6. Privileged user activity monitoring to enforce governance and prevent unauthorized modifications
  7. File server auditing to ensure data integrity and detect unauthorized access
  8. ML-based anomaly detection to identify deviations from secure operational patterns
  9. Enforce strong authentication (MFA, conditional access) to ensure resilient system design
  10. Password policy enforcement to prevent weak credential use
  11. Context-based authentication aligning with governance principles
  12. Monitoring of cloud system changes (Azure AD, Exchange, SharePoint, Teams)
  13. Audit trails for permissions and role changes supporting governance and good practices
  14. Data access insights to validate proper system segmentation and data minimization
  15. Backup integrity enforcement to ensure system resilience
  16. Multi-point-in-time recovery to restore secure system states
  17. Audit trails for backup & restore events supporting governance documentation

Article 50 Good practices and governance

Compliance actions Report and Evidences IAM Controls

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.

  1. Azure AD Role & Permission Change Reports
  2. Exchange/SharePoint/OneDrive Access & Sharing Reports
  3. Teams Activity & Change Logs
  4. Backup Integrity Reports
  5. Backup Policy Change Reports
  6. Restore Activity & Verification Logs
  1. Implement Role-Based Access Control (RBAC) and administrative delegation aligned with governance rules
  2. Automate user lifecycle workflows to maintain a clean, controlled identity environment
  3. Maintain auditable approval workflows for any access or attribute modification
  4. Perform periodic access certifications for continuous governance compliance
  5. Enforce real-time auditing of all configuration, identity, and policy changes
  6. Monitor privileged user behavior and enforce segregation-of-duties governance
  7. Maintain tamper-evident logs for all AD governance activities
  8. Use ML-based anomaly detection to identify governance violations or insider misuse
  9. Enforce strong authentication governance through MFA, conditional access, and password rules
  10. Provide auditable self-service changes for user attributes, ensuring traceability
  11. Enforce context-based authentication policies that reflect governance requirements
  12. Monitor cloud identity governance, including Azure AD role changes
  13. Audit permission changes across Exchange, SharePoint, OneDrive, and Teams
  14. Provide visibility on data sharing, supporting governance transparency
  15. Enforce backup governance, including retention rules and secure storage
  16. Maintain immutable backup logs to demonstrate compliance
  17. 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.

 
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