In an increasingly digital corporate landscape, data has become a highly valuable strategic asset. In this context, the Human Resources (HR) sector emerges as a key player in data protection. After all, HR operates directly at the intersection of an organization's two most valuable assets: People and their personal dataIn this article, you will understand how the HR sector can (and should) lead the movement for privacy and data protection within organizations.
The employee lifecycle: From entry to exit, everything is data processing.
The leading role of HR in data protection becomes evident when we analyze the employee lifecycle. The HR area is the entry and exit point for the organization. From recruitment to termination, data is processed—much of it sensitive.
During the selection and recruitment process, for example, data such as name, phone number, email, home address, academic background, psychometric test results, and even health data are already processed. Upon hiring, inclusion in corporate benefits requires the provision of identification documents, bank details, and dependent information.
Throughout the hiring process, performance reviews, training, and organizational climate initiatives also require the constant processing of this data.
Finally, upon termination, data related to the contract termination is processed, such as the type of termination, settlement terms, internal and external communications regarding the departure, as well as data used for issuing legal documents, calculating severance payments, submitting information to eSocial (Brazilian social security system), updating CAGED (Brazilian employment database), and recording any labor or judicial agreements. In addition, HR typically conducts exit interviews, in which information is collected about the reasons for leaving and the employee's perceptions of the experience, which also constitutes the processing of personal data.
In this sense, it is essential that HR observes the legal requirements of the LGPD (articles 7 and 11), adopts technical and administrative protection measures (article 46), and follows best practice rules (article 50). Mapping data processing activities, categorizing the data processed, identifying data subjects, and clearly defining purposes and retention periods, as well as sharing and disposal methods, are fundamental to ensuring compliance.
Because HR needs to be aware.
The HR area, due to its direct handling of a high volume of data, is positioned as one of the most critical areas from a data protection perspective. Threats and risks are diverse and can originate from physical vulnerabilities, such as inadequate document storage, lack of access control to files, and improper document disposal; and from technological vulnerabilities, such as information leaks if an email is intercepted or accessed by unauthorized third parties, unauthorized access to systems used by the HR area, among others.
The Human Resources area is a highly attractive target for malicious actors. It's important to highlight that, according to a survey released by Mimecast, human error was the leading cause of cyberattacks in 2024, accounting for 95% of data breaches.
Security incidents involving data under the custody of HR can compromise internal credibility and negatively impact the organization's business. It's important to remember that the repercussions are not limited to the organization—which may suffer sanctions from the ANPD (Brazilian National Data Protection Authority), lawsuits, and reputational damage. The HR employee can also be held liable, including facing dismissal for just cause under Article 482 of the CLT (Brazilian Labor Code), if they fail to comply with internal data protection guidelines, especially after formal training.
Practical and structured solutions
Compliance with the LGPD (Brazilian General Data Protection Law) requires more than just isolated actions. It is essential to implement and maintain a Data Protection and Privacy Governance Program, as outlined in Article 50 of the aforementioned legislation. This program constitutes a continuous operational cycle that aligns best practices in corporate governance with current legal provisions, transversally incorporating the principles of information security, risk management, and... accountabilityBut how do we apply this in practice?
The practical application of the General Data Protection Law (LGPD) in the corporate environment can be structured in two distinct phases. The first refers to the compliance implementation phase, when all personal data processing activities are mapped. In this initial stage, the documentation required by law is prepared, such as the Record of Personal Data Processing Operations (ROPA) and the Personal Data Protection Impact Assessment Report (RIPD).
Furthermore, internal policies are developed, and existing processes and procedures are reviewed or reformulated to ensure their adherence to legal requirements. During this first phase, historically entrenched inadequate practices in organizational routines – such as excessive data collection, prolonged and insecure storage, indiscriminate sharing, and improper disposal of information – must be identified, corrected, and replaced.
Once the initial adaptation phase is completed – focused on document structuring, process review, and risk mitigation – a second stage begins, marked by the systemic incorporation of privacy and data protection into institutional routines, in accordance with the concepts of Privacy by Design, Privacy by default e Privacy by Redesign.
It is noteworthy that implementing a continuous training, awareness, and education program is essential to ensure that employees act in accordance with legal and organizational guidelines regarding the protection of personal data. In this context, gamification stands out as an innovative methodological strategy capable of enhancing engagement and knowledge retention through interactive experiences.
Conclusion
Implementing structural changes, especially those involving abandoning established practices, is never easy. But, in the context of the LGPD (Brazilian General Data Protection Law), neglecting these changes is a risk that no organization can afford to take.
With the enactment of the General Data Protection Law (LGPD), respect for privacy and data protection has ceased to be a choice and has become a legal and ethical obligation. For organizations that have historically not cultivated a culture focused on protecting the privacy of their employees, customers, partners, and other stakeholders, the imposition of rules on the subject can provoke resistance and insecurity, especially among professionals who deal daily with activities related to the processing of personal data. In this context, it becomes essential to adopt pedagogical and communicational strategies that promote engagement, clarification, and progressive adaptation to the new regulatory reality.
The behavior known as "Gabriela syndrome"—"I was born this way, I grew up this way, I am this way, I will always be this way"—which symbolizes resistance to evolution and the adoption of new practices, must be actively combated in the context of data governance.
Therefore, HR is more than just a process operator—it's a culture-shaping agent. When the sector performs with excellence, it directly influences other areas of the company. As the gateway for employees and a constant link with leadership, HR is the ideal vector for spreading a data protection mindset at all levels. This action not only mitigates legal and regulatory risks but also strengthens brand reputation and stakeholder trust.
Does your company already train HR to act as guardian of personal data? The time to act is now.
