ATTENTION: Condominiums and Administrators must comply with the General Data Protection Law
- Miscellaneous
- Equipe Editorial
The LGPD (Brazil’s General Data Protection Law) establishes rules for the processing of personal data — such as collection, use, storage, and sharing — and also applies to commercial and residential condominiums, regardless of whether they are for-profit.
Condominium administrators, also subject to the LGPD, must pay extra attention in many cases, as they often centralize, process, and store personal data of residents, visitors, and employees, both digitally and physically.
Failure to comply with LGPD regulations may result in civil liability, administrative penalties from the ANPD, and fines that directly impact the condominium’s budget—and, consequently, directly affect the condominium owners.
1. Examples of personal data processed by condominiums and administrators
- Condominium owners’ registration data (name, CPF, email, telephone number)
- Visitor data (name, document, entry and exit time)
- Security camera images (internal and external monitoring)
- Default and collection records
- Meeting Records and Minutes (with identification of those present)
- Information and contacts in WhatsApp groups
- Contractual and financial information of residents and the condominium
2. Penalties provided for in the LGPD
- Warning with deadline for correction
- Fine of up to 2% of the entity’s revenue, limited to R$50 million per violation
- Daily fine, until regularization
- Publication of the infraction and risk to the reputation of the condominium and the administrator
- Blocking of personal data related to the infringement until its regularization
- Partial suspension or suspension of the exercise of the activity of processing personal data
- Partial or total prohibition of the exercise of activities related to data processing
- Deletion of personal data to which the infringement refers
If the landlord is negligent, he or she may be held civilly liable and have to compensate the condominium — as provided for in the Civil Code.
3. How condominiums and property management companies can adapt to the LGPD
- Appointment of a Data Controller
- Define and document the purpose of the data collected
- Need to keep a record of processing activities
- Establish rules for secure storage and controlled access
- Avoid unnecessary exposure (visible lists or data in open groups)
- Create and publicize a channel for serving data subjects (residents, employees, visitors)
- Develop a Condominium Privacy Policy, including the administrator’s responsibilities
4. What about training?
It is the responsibility of the landlord or administrator:
- Seek expert guidance or free online courses on the LGPD
- Train condominium employees (doormen, caretakers, assistants) with guidelines for:
- Do not share personal information in WhatsApp groups
- Do not leave lists exposed in places of circulation
- Know how to handle requests for access, correction, or deletion of data
- Good practices for security and personal data protection
- Also train the administrator’s team, especially those who deal with registrations, systems, meetings and collections.
5. Cybersecurity Culture in the Team
Provide regular training and encourage your team to adopt a proactive security mindset. Conscientious developers are the first line of defense against exploits and attacks.
Compliance with the LGPD is NOT an obligation exclusive to large companies. It protects everyone’s privacy — including those in your condominium and in the daily operations of the property management company.
Do you have any questions or need guidance?
T2M can help.
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