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Five years into the enforcement of Brazil's General Personal Data Protection Law, the data protection officer role has evolved from a novel legal requirement into a central figure in corporate governance. This role, tasked with stewarding an organization's most valuable and vulnerable asset — data — is now at a critical inflection point.
A new study, "Profile of a DPO in Brazil 2025," conducted by Rede Líderes and Opice Blum, pulls back the curtain on the realities of this demanding position. The survey of more than 200 data protection officers from diverse sectors reveals a professional who is more integrated and respected than ever but is often navigating a landscape of high-stakes risk with limited resources.
The report paints the Brazilian DPO as a professional embedded in critical organizational functions yet constrained by challenges that demand attention from senior leadership. While progress is evident, the gap between responsibility and resources highlights the next frontier for data protection maturity in Brazil.
The overburdened specialist
One of the survey's most telling findings is the hybrid nature of the DPO role. A mere 27% of respondents act exclusively as their organization's DPO. The vast majority juggle this function with other responsibilities, primarily within the legal and compliance departments. The data shows that 35% of DPOs are housed in the legal department, with another 23% in compliance.
This accumulation of roles naturally raises concerns about functional independence and potential conflicts of interest. While 66% of the surveyed DPOs affirm they have the necessary functional independence, one-third report their autonomy is either partially compromised or non-existent.
The challenges are palpable; DPOs cite pressure to approve high-risk activities or being required to seek prior approval from other directors before acting. This structural tension places many DPOs in a precarious position, caught between their duty to the law and the operational demands of their other roles.
High perceptions vs. stark realities
A paradox emerges from the report's data: a self-assessment of maturity set against a backdrop of high risk and low investment. A majority of DPOs, 63% of them, believe their organization has achieved a "high" or "very high" level of maturity in its data protection governance program. This confidence suggests that the principles of the LGPD have taken root and that foundational governance structures are in place.
However, this perception is contrasted by two different realities. First, 56% of these organizations engage in data processing activities that their DPOs classify as "high" or "very high" risk. Furthermore, the study reveals a significant cohort — 21% of respondents — working in organizations admit they have low to medium maturity while simultaneously handling high-risk data processing.
Second, this high-risk environment is being managed with low levels of investment. Among large companies with over 1,000 employees, 74% operate with a data protection budget of less than BRL600,000 per year — approximately USD110,000. In comparison to global counterparts of a similar size, which invest between USD1 million and USD7 million annually, this seems to be below what should be expected. The situation is even worse for 30% of surveyed DPOs, who reported no dedicated budget whatsoever.
A team of one
The resource gap extends to human capital. The "lone wolf" DPO is a common reality in Brazil, with 22% of respondents reporting they work entirely alone. Even when a team exists, it is typically small: 69% of DPOs have a dedicated privacy team of five or fewer people. Among large enterprises — organizations where complex data flows are the norm — 55% have privacy teams of three or fewer individuals.
This lean staffing model stands in contrast to the international landscape, where average privacy team sizes range from 26 employees in Europe to 31 in Asia. It's no surprise, then, that when asked about their greatest challenges, 17% of surveyed DPOs ranked "lack of support staff," 16% ranked "lack of dedicated budget," and 15% ranked "accumulation of functions" as their top three obstacles.
Bright spots on the horizon
Despite the significant structural challenges, the report highlights clear indicators that the DPO role is not only maturing but is becoming deeply integrated into the corporate fabric.
One of the most positive findings is the DPO's involvement in strategic decision-making: 67% of Brazilian DPOs state they are "always" consulted on relevant data protection matters before decisions are made. This figure is notably higher than in the European Union, where only 21% of DPOs report the same consistent level of early involvement.
Furthermore, 80% of DPOs are involved in security incidents from the moment of initial identification. This demonstrates their role is seen as central when the organization's data — and reputation — is on the line.
The report offers the most comprehensive picture to date of this profession in Brazil, revealing a cohort of dedicated, highly integrated, and increasingly influential professionals who are punching well above their weight class.
While these findings paint a broad picture, the full study delves deeper into sector-specific trends and the granular details of a DPO's daily challenges. Understanding these nuances helps organizations not only ensure compliance but also build a resilient and trust-centric data strategy. As Brazil's digital economy matures, the success of its businesses will increasingly depend on empowering the DPOs who stand on the front lines of digital trust.
Henrique Fabretti Moraes, CIPP/E, CIPM, CIPT, CDPO/BR, FIP, is a partner at Opice Blum.
