BR LGPD Arts. 17-18 and 39 - parental-supervision controls and safeguards

Where this comes from

Who it applies to

What engineering work it implies

Evidence an auditor expects

• Assessment documentDocument review

  Provide protective, accessible and non-manipulative parental-supervision controls — scoped assessment and minimized evidence

  Assess Article 39's modulation by the actual service's features, provider influence, user numbers and size before relying on its limited relief for Articles 17 and 18. Dispensation requires the eligible editorial-control or previously licensed-content provider class AND all four safeguard conditions: classification or required alternative age adequacy/harm signalling, transparent age classification, accessible parental mediation covering age-based content, personal data, user interaction and commercial transactions, and accessible reporting channels. Preserve replacement safeguards and non-listed duties including Articles 7, 8 and 16; a generic service label or one control is insufficient. Under Article 17, provide accessible, easy-to-use parental-supervision settings/tools appropriate to available technology and the product/service nature and purpose, readily accessible parent/guardian information, clear visible notice when supervision is active and which controls apply, and functions to limit and monitor time of use. Respect best interests and progressive development of capacities. Prior ANPD appreciation is permitted but is not a prerequisite to using the tools or making the service available; current minimum standards still require verification. Apply Article 17 section 4's highest available protective defaults: restrict unauthorized user communications; limit artificial usage-extension features such as autoplay, time rewards and notifications; offer healthy-use monitoring and immediate time visualization/limits; allow disabling personalized recommendations; restrict geolocation sharing and give clear prior tracking notice; and promote digital/media education. Regularly review AI tools with specialists and competent bodies against technical child/adolescent safety and suitability criteria, with the ability to disable nonessential functions. Where technically feasible, provide age-appropriate, evidence-based emotional-support/wellbeing resources or service connections, especially for identified psychosocial-risk interactions. Preserve these conditional duties without inventing a universal audit interval, diagnosis requirement or unrestricted collection of children's intimate disclosures. Under Article 18, parental tools must enable account/privacy viewing, configuration and management, restricting purchases/financial transactions, identifying adult profiles communicating with the child/adolescent, consolidated total-use-time metrics, accessible and appropriate safeguard activation/deactivation controls, and information/control options in Portuguese. Provide clear information appropriate to differing ages, capacities and developmental needs without encouraging safeguards to be disabled or weakened. Do not design, modify or manipulate interfaces with the purpose or effect of undermining user autonomy, decisions or choices, especially where supervision or safeguards are weakened. Assess adult-profile identification and consolidated metrics proportionately; this is not permission to disclose all conversations or detailed behavior histories to any requester. Use synthetic or sanitized assessment cases and minimized configuration, access, control and review evidence. Exclude real child identities, conversations, images, recordings, precise locations and raw personal-data reports from ordinary task attachments, exports and general logs. Keep any legally necessary sensitive operational material in a separately authorized, purpose-limited process with assessed access and retention. This is an engineering evidence-minimization safeguard, not a prescribed fixed log schema or retention period. Verify current ANPD implementing requirements and qualified Portuguese source review. Lei 15.211/2025 commenced on 17 March 2026 following Lei 15.352/2026; do not infer all historical legal outcomes or full ECA Digital compliance from this record.

Questions people ask

Does BR LGPD Arts. 17-18 and 39 - parental-supervision controls and safeguards apply to my service?

It applies when Brazil ECA Digital assessed fact Q_BR_ECA_CHILD_ACCESS: YES. It does not apply where Brazil ECA Digital assessed fact Q_BR_ECA_ART39_SERVICE_CLASS: YES.

From when does this apply?

BR LGPD Arts. 17-18 and 39 - parental-supervision controls and safeguards applies from 17 March 2026. Its current status is: in force.

What evidence does an auditor expect?

Provide protective, accessible and non-manipulative parental-supervision controls — scoped assessment and minimized evidence.