COVID-19: Brazilian Regulator’s Principles for Processing Geolocation Data

Sharing consumers’ geolocation data by telecom operators does not violate the Federal Constitution or LGPD when done in an aggregated and anonymized way (i.e., for statistical purposes); the terms of the sharing agreement must be made public, the data can only be used for a concrete, specific and legitimate objective (rather than generic justifications such as “fighting the pandemic”), and the lifecycle of the processing must be clearly determined in its entirety (i.e., beginning, means and end of processing).