To meet LGPD, GDPR and ISO 27001 requirements in a cloud-only infrastructure, start by mapping personal data, defining controller/processor roles, and restricting providers to compliant regions. Then implement strong IAM, encryption, monitoring, and incident response. Document everything as evidence and regularly reassess risks, contracts, and cloud services as your environment evolves.
Essential compliance priorities for cloud-only infrastructures
- Define lawful basis, controller/processor boundaries and joint responsibilities for all cloud workloads handling personal data.
- Apply data residency, classification and encryption with keys and regions controlled under your governance model.
- Centralize identity, access and privileged access management across all cloud-native services and tenants.
- Enable tamper-evident logging and monitoring with retention aligned to LGPD, GDPR and ISO 27001 evidence needs.
- Harden vendor risk management and contracts to cover sub‑processors, audits, breach support and data subject rights.
- Operationalize policies via tested incident response, DPIAs, continuous assurance and periodic control reviews.
Mapping personal data flows and responsibility boundaries
This preparation fits organizations already running or migrating most workloads to public cloud (IaaS, PaaS, SaaS). It is not suitable to skip mapping when you rely heavily on shadow IT or unmanaged SaaS; in that case, first inventory and rationalize tools, then run a structured data flow mapping exercise.
Focus on identifying what personal data is processed in each cloud service, why (purpose), where it flows, and who is responsible (controller vs processor). This underpins LGPD and GDPR compliance and directly supports ISO 27001 controls on asset management, risk assessment and third‑party security.
| Task | Responsible role | Main artifact | Regulation / standard link |
|---|---|---|---|
| Identify cloud services with personal data | IT owner, Data Protection Officer | Cloud asset register | LGPD arts. 37-38; GDPR arts. 30, 24; ISO 27001 Annex A.5 |
| Document purposes and legal bases | Data Protection Officer, business owner | RoPA and purpose matrix | LGPD arts. 7-11; GDPR arts. 6, 9 |
| Classify controller vs processor roles | Legal, DPO | Role assignment register | LGPD arts. 5, 39; GDPR arts. 4, 24, 28 |
| Map cross‑border transfers between regions | Cloud architect, DPO | Data flow diagrams | LGPD arts. 33-36; GDPR arts. 44-49 |
| Identify high‑risk processing for DPIA | Risk manager, DPO | DPIA candidate list | LGPD art. 38; GDPR art. 35; ISO 27001 Annex A.5.7 |
For many Brazilian companies, using consultoria lgpd para empresas em cloud helps to structure this mapping and ensure terminology and responsibilities are aligned with both LGPD and GDPR language, especially when multiple business units share cloud platforms.
Implementing data residency, classification and encryption controls
To implement effective data residency, classification and encryption in a cloud-only environment you will need clear policies, tooling access and cross‑functional cooperation. Start by defining which countries and regions are allowed for storage and processing, then configure your cloud platforms so non‑compliant regions cannot be used accidentally.
Required inputs and capabilities include at least:
- Approved list of countries/regions for personal data processing, aligned with LGPD and GDPR transfer rules.
- Data classification policy with levels (for example, public, internal, confidential, sensitive personal) and handling rules.
- Cloud provider features for region restrictions, encryption at rest, encryption in transit and key management (KMS or HSM).
- Access to DNS, networking and deployment pipelines, so you can block non‑compliant regions at code and infrastructure level.
- Integration with serviços de adequação gdpr e lgpd nuvem, when you need external validation of residency and encryption designs.
| Control area | Concrete configuration | Owner | Evidence | Reference |
|---|---|---|---|---|
| Data residency | Restrict allowed regions in cloud accounts and deployment templates | Cloud platform team | Policy-as-code, screenshots of region restrictions | LGPD arts. 33-36; GDPR arts. 44-49; ISO 27001 A.5.20 |
| Classification | Tag resources and storage with classification labels | Data owner, DevOps | Tagging standards, inventory with labels | LGPD arts. 6, 46; GDPR arts. 5, 32; ISO 27001 A.5.12 |
| Encryption at rest | Enable default encryption on storage, databases, backups | Cloud security engineer | Configuration baselines, CMDB attributes | LGPD art. 46; GDPR art. 32; ISO 27001 A.8.24 |
| Key management | Use centralized KMS with role‑based key access | Security team | Key inventory, key access logs | GDPR art. 32; ISO 27001 A.8.28 |
| Encryption in transit | Force TLS for all external and internal endpoints | Network and DevOps teams | TLS configuration reports, automated tests | LGPD art. 46; GDPR art. 32; ISO 27001 A.8.21 |
Identity, access and privileged access management in cloud-native services
Before changing access controls in production, prepare to avoid lockouts and unsafe misconfigurations.
- Document current admin accounts and break‑glass procedures.
- Ensure at least two people understand each cloud provider's IAM model.
- Test new IAM policies in non‑production first.
- Plan communication to affected users and application owners.
- Coordinate with any empresa especializada em segurança da informação e conformidade cloud that supports you.
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Centralize identities and enforce strong authentication
Integrate your cloud tenants with a central identity provider (IdP), using SSO and MFA for all privileged roles and console access. Avoid long‑lived local users in the cloud provider whenever possible.
- Enable MFA for all human users.
- Block password‑only console logins for admins.
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Design role-based access aligned with business functions
Create roles that match job functions (DevOps, DBA, security, support) and only grant the permissions needed. Separate duties so that no single role can deploy, approve and monitor sensitive workloads end-to-end.
- Use groups mapped from your IdP to cloud roles.
- Define clear ownership for each application and environment.
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Control machine identities, service accounts and secrets
For workloads, prefer short‑lived credentials and managed identities instead of static keys. Store any keys or passwords in a secrets manager integrated with your cloud provider.
- Inventory existing access keys and rotate or remove them.
- Enforce secret scanning in CI/CD pipelines.
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Harden privileged access workflows
Use just‑in‑time elevation for highly privileged roles and log all admin actions. Limit direct access to production and use bastion or privileged access workstations where feasible.
- Require approvals for elevation to highly privileged roles.
- Disallow shared admin accounts; use named identities.
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Implement access review and recertification routines
On a regular schedule, review who has access to which resources, focusing on personal data repositories, logs and security consoles. Remove dormant accounts and unnecessary privileges.
- Automate reports using your IdP and cloud APIs.
- Include third‑party access in reviews.
| PAM / IAM control | Primary owner | Verification artifact | LGPD / GDPR / ISO 27001 link |
|---|---|---|---|
| MFA for all admins | Security operations | MFA policy export, IdP configuration | LGPD art. 46; GDPR art. 32; ISO 27001 A.5.17 |
| Role-based access control | Cloud platform team | Role definitions, mapping to groups | LGPD art. 46; GDPR arts. 24, 25, 32; ISO 27001 A.5.15 |
| Service account governance | DevOps, security engineer | Service account inventory, key rotation logs | GDPR art. 32; ISO 27001 A.8.27 |
| Privileged access workflows | IT operations, security | Documented procedures, access request records | LGPD art. 46; GDPR art. 32; ISO 27001 A.5.8 |
| Periodic access reviews | System owners, DPO oversight | Review logs, remediation tickets | LGPD arts. 46, 50; GDPR arts. 24, 32; ISO 27001 A.5.10 |
Logging, monitoring and building immutable audit evidence
Use this checklist to verify that logging and monitoring support LGPD, GDPR and ISO 27001 obligations, including incident detection, investigation and demonstration of accountability, while avoiding excessive logging of personal data.
- All cloud control‑plane, data‑plane and application logs are enabled and collected centrally with time synchronization.
- Log storage uses write‑once or immutability features, with retention aligned to legal and business needs.
- Security events (such as unusual login patterns, privilege escalations, failed access to personal data) trigger alerts and triage.
- Logs do not store more personal data than necessary; masking and minimization are applied where feasible.
- Access to logs is restricted and monitored, especially for logs containing personal identifiers.
- Playbooks define how to use logs during incidents, DPIAs and audits for LGPD and GDPR.
- Monitoring covers cloud vendor health, regional outages and data residency drifts that may impact compliance.
- Evidence packages (for example, screenshots, exports, reports) can be generated quickly for regulators or clients.
| Logging capability | Owner | Evidence | Regulatory alignment |
|---|---|---|---|
| Centralized log collection | Security operations center | SIEM configuration, ingestion dashboards | LGPD art. 46; GDPR art. 32; ISO 27001 A.8.16 |
| Immutable storage | Cloud platform engineer | Bucket policies, retention locks | ISO 27001 A.8.12, A.8.23 |
| Alerting on key security events | Security engineer | Alert rules, incident tickets | LGPD arts. 46, 48; GDPR arts. 32, 33 |
| Log access control and minimization | DPO, security architect | Access lists, masking configurations | LGPD arts. 6, 46; GDPR arts. 5, 25, 32 |
| Audit reporting | Compliance officer | Standardized reports for audits | LGPD art. 37; GDPR art. 30; ISO 27001 A.5.36 |
Vendor risk management and enforceable cloud contracts
Common mistakes when handling vendor risk and cloud contracts often undermine otherwise strong technical controls, especially when relying on soluções de compliance em nuvem para lgpd e gdpr that are not fully integrated with legal and procurement processes.
- Assuming major cloud providers always cover LGPD and GDPR specifics without reviewing their data processing agreements for Brazilian contexts.
- Not identifying sub‑processors used by the main cloud vendor, leading to hidden cross‑border transfer risks.
- Leaving data subject rights handling (access, deletion, portability) undefined between controller and processor in the contract.
- Omitting clear security baselines, audit rights and response times for incidents in service level agreements.
- Failing to align retention and deletion obligations in the contract with your internal backup and archival policies.
- Not verifying whether the vendor's implementação iso 27001 em infraestrutura cloud scope actually includes the services you use.
- Ignoring exit strategies, such as data export formats, secure deletion guarantees and assistance fees at termination.
- Relying purely on certificates without reviewing independent reports or questionnaires to understand residual risks.
- Forgetting to update contracts when you add new high‑risk processing or regions to existing cloud services.
| Vendor risk step | Role | Key document | Compliance linkage |
|---|---|---|---|
| Perform structured vendor assessment | Security, procurement | Security and privacy questionnaire | LGPD arts. 46, 39; GDPR arts. 28, 32; ISO 27001 A.5.19 |
| Negotiate data processing agreement | Legal, DPO | DPA with LGPD/GDPR clauses | LGPD arts. 39-41; GDPR art. 28 |
| Confirm certifications and scope | Compliance officer | ISO 27001 SoA, audit reports | ISO 27001 A.5.36 |
| Define incident notification terms | Legal, security | Contractual SLAs for breaches | LGPD art. 48; GDPR arts. 33-34 |
| Plan contract exit and data return | IT, legal, business owner | Exit plan, data migration procedures | LGPD arts. 15-18; GDPR arts. 17, 20 |
Operationalizing policies: incident response, DPIAs and continuous assurance
Different operational models can satisfy LGPD, GDPR and ISO 27001 expectations in a cloud-only infrastructure. Choose the variant that best fits your size, risk profile and available skills, and avoid over‑engineering processes you cannot maintain.
- In‑house governance with targeted external support – Suitable for mid‑sized organizations with established security and legal teams. You run incident response, DPIAs and control testing internally, while using consultoria lgpd para empresas em cloud for complex cross‑border issues or deep technical reviews.
- Co‑managed model with a specialized provider – A good option when you have limited cloud security skills. An empresa especializada em segurança da informação e conformidade cloud co‑manages SOC, incident handling, DPIA templates and ISO 27001 control monitoring, while you keep decision‑making and accountability.
- Outsourced monitoring with strong internal DPO oversight – Works when your priority is 24×7 detection and response. You outsource SIEM/SOC to a provider but keep DPIAs, policy decisions and regulator communications under the Data Protection Officer and legal team.
- Product‑centric approach for smaller teams – For smaller companies, focus on a minimal set of well‑configured cloud‑native tools and serviços de adequação gdpr e lgpd nuvem that provide built‑in assessments, with lightweight manual reviews each quarter instead of heavy documentation.
| Operational model | Best for | Main strengths | Main risks |
|---|---|---|---|
| In‑house governance | Organizations with mature IT and legal | High control, deep business knowledge | Requires ongoing investment in skills and tooling |
| Co‑managed with specialist | Growing companies in fast cloud adoption | Balance of expertise and internal ownership | Need clear RACI to avoid gaps |
| Outsourced monitoring | Teams needing 24×7 coverage | Rapid detection and response capabilities | Potential misalignment on risk priorities |
| Product‑centric minimal | Smaller teams with limited budget | Simple to run, fewer moving parts | Less flexibility for complex requirements |
Practical answers on LGPD, GDPR and ISO 27001 in cloud environments
How do LGPD and GDPR apply differently in a cloud-only infrastructure?
LGPD and GDPR share core principles, but LGPD focuses on Brazilian data subjects and provides specific rules for the national authority. In a cloud-only setup, you must consider both laws when processing EU and Brazilian data, aligning contracts, transfers and security controls to the stricter requirements.
Is ISO 27001 certification mandatory for my cloud providers?
ISO 27001 certification is not legally mandatory but is widely used to demonstrate structured security management. For critical cloud services, prioritize vendors with relevant and up‑to‑date ISO 27001 scopes and obtain their Statement of Applicability and audit reports to understand coverage and gaps.
Can I rely only on cloud-native security tools to be compliant?
Cloud-native tools are usually strong building blocks but do not guarantee compliance on their own. You still need governance, policies, contracts, DPIAs, training and documented procedures to meet LGPD, GDPR and ISO 27001 expectations and to prove accountability in audits or investigations.
How should I handle data subject requests in a cloud environment?
Identify which cloud services store personal data and ensure you can search, export, correct and delete records across them. Define end‑to‑end workflows, including vendor support, and document how you authenticate requesters, log actions and respond within legal timeframes for LGPD and GDPR.
What is the safest way to manage encryption keys in public cloud?
Prefer managed key management services with strict role-based access and logging, combined with separation of duties between cloud admins and security teams. For highly sensitive workloads, evaluate customer‑managed or external HSMs, ensuring that key lifecycle and backup procedures are documented and periodically tested.
Do I always need a DPIA for cloud projects?
You need DPIAs when processing is likely to pose high risk to individuals, such as large-scale profiling or sensitive data. Many smaller or low‑risk cloud workloads may not require a full DPIA, but documenting a risk screening decision is still recommended for accountability.
How often should I review my cloud compliance controls?
Review core controls, such as IAM, logging and vendor risk, at least annually and whenever you add major new cloud services or process new types of personal data. For high‑risk environments, quarterly or continuous automated checks are preferable to capture rapid cloud changes.