LGPD Article 12: anonymised data is not personal data unless the anonymisation can be reversed with reasonable efforts (Lei Geral de Proteção de Dados, Law No. 13,709 of 14 August 2018, Art. 12 and Art. 12, par. 1 (ANPD English translation))
Data that has been truly anonymised can be licensed outside the LGPD, but only if re-identification would need more than reasonable cost and time with available technology. A holder that merely masks names while keeping rare combinations (employer, dates, free text) has personal data and stays inside the law.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Anonymized data shall not be deemed personal data for purposes of this Law, except when the anonymization process to which they have been submitted is reversed, using exclusively own means, or when it may be reversed applying reasonable efforts. ... The determination of what is considered reasonable shall take objective factors into account, such as cost and time required to reverse the anonymization process, according to the technologies available, and the exclusive use of own means.”
Where it was read
Also read from the same source
- LGPD Article 7: the legal bases for processing personal data, including consent (I) and the controller's legitimate interest (IX) (Lei Geral de Proteção de Dados, Law No. 13,709 of 14 August 2018, Art. 7, I and IX (ANPD English translation))
- LGPD Article 33: the only cases in which personal data may be transferred abroad (Lei Geral de Proteção de Dados, Law No. 13,709 of 14 August 2018, Art. 33, I, II and VIII (ANPD English translation))
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide