Public Law and Compliance
Compliance
Integrity programs, data protection and response to internal investigations.
An integrity program is not a filed document: it is the set of controls a company can show that it applies. The difference appears when an oversight body asks what was done about an indication of wrongdoing — and the answer has to come with a record.
Situations the area handles
- Company that contracts with government without a structured integrity program.
- Indication of irregularity requiring an internal inquiry with preservation of evidence.
- Processing of personal data with no defined legal basis or no record of operations.
- Security incident involving personal data and the duty to notify the ANPD.
- Reporting channel with no investigation procedure and no protection for the reporter.
- Third parties and intermediaries engaged without integrity due diligence.
- Negotiation of a leniency or cooperation agreement with an oversight body.
What the work produces
- Risk assessment and design of an integrity program.
- Codes of conduct, internal policies and staff training.
- Compliance with the Lei Geral de Proteção de Dados, with mapping and records of operations.
- Internal investigation with a report and recommended measures.
- Integrity due diligence on third parties.
- Representation in administrative liability proceedings.
When to seek it
Before an inspection, while the program can still be built without haste. Faced with a concrete indication, immediately: how the inquiry begins determines the value of the evidence produced.
Talk about compliance
Describe the transaction and the stage it is at. The reply indicates what needs to be verified before the decision.