Use the Brazilian mechanism explicitly
ANPD’s international-transfer resources describe Resolution 19/2024 and mechanisms including standard contractual clauses, adequacy decisions, and approved alternatives. Its guidance distinguishes Brazilian standard clauses from foreign clauses that would need recognition as equivalent. Do not assume a contract containing EU clauses automatically supplies the Brazilian transfer mechanism. Check the current ANPD repository and the scope of any applicable decision when the transaction is reviewed.
Keep the processing basis separate
A transfer route answers only part of the licensing problem. Prepare the basis for the original collection and the proposed training use, the notice history, source agreements, data categories, and people affected. Ask Brazilian counsel whether the actual transaction is supported under the LGPD and whether sensitive information or children’s material requires different treatment. A foreign buyer’s promise to protect records does not establish your right to sell the corpus.
Prepare an operational contract schedule
List the exporter and importer, access countries, onward recipients, purposes, retention limits, and security responsibilities. For Portuguese-language material, document regional coverage and annotation quality without using personal examples in marketing. Keep an exclusion log for confidential documents, unlicensed attachments, and records with uncertain collection authority. If standard clauses are the selected route, preserve the required text and obtain advice on integrating the commercial licence without conflicting terms.
- Review current ANPD adequacy and equivalent-clause decisions.
- Record the exact transfer mechanism and applicable contract version.
- Distinguish evaluation access from production model-training permission.
- Specify how the buyer reports new processors or source-rights complaints.
Review before release
Sources reviewed on 19 October 2026. This is a preparation checklist, not legal clearance, tax advice, or confirmation that an AI lab accepts suppliers from this jurisdiction. Ask qualified local counsel to review the actual dataset, collection history, proposed training purpose, recipient, and current rules before releasing personal data.