Review personal data sent outside the company

Covers: LGPD (Brazil), art. 46 (security measures)

Use in VulnifyOpens in monitor mode by default. Nothing is created until you click Apply.

What it does

Any agent action that sends data from resources you classify as customer personal data (CUSTOMER_PII) to an external email or API waits for a human approval. Related to LGPD art. 46. Does not determine whether a destination is outside Brazil; international transfers have separate requirements under LGPD arts. 33–36.

Notes

Matching depends mainly on the resource labels you apply in Vulnify, plus optional content checks for some common identifiers (such as CPF numbers or email addresses); it is not a reliable detector of personal data. Test in monitor mode first.

Default mode in this template: ENFORCE. The “Use in Vulnify” link preselects monitor mode; you can switch to enforce before applying.

Policy

Policy JSON (API)

{
  "name": "lgpd-review-external-personal-data-transfer",
  "description": "Any agent action that sends data from resources you classify as customer personal data (CUSTOMER_PII) to an external email or API waits for a human approval. Related to LGPD art. 46. Does not determine whether a destination is outside Brazil; international transfers have separate requirements under LGPD arts. 33–36.",
  "enabled": true,
  "action": "ANY",
  "resource": "CUSTOMER_PII",
  "condition": {
    "destination": "EXTERNAL"
  },
  "decision": "REVIEW",
  "approverRoles": [
    "OWNER",
    "ADMIN"
  ],
  "mode": "ENFORCE"
}

Policy YAML (CLI policy file)

apiVersion: vulnify.io/v1
kind: Policy
metadata:
  name: lgpd-review-external-personal-data-transfer
spec:
  description: "Any agent action that sends data from resources you classify as customer personal data (CUSTOMER_PII) to an external email or API waits for a human approval. Related to LGPD art. 46. Does not determine whether a destination is outside Brazil; international transfers have separate requirements under LGPD arts. 33–36."
  enabled: true
  action: ANY
  resource: CUSTOMER_PII
  condition:
    destination: EXTERNAL
  decision: REVIEW
  approverRoles:
    - OWNER
    - ADMIN
  mode: ENFORCE

Example test cases

Case	Input	Expected decision
customer data to external API	`{"agent":"example-agent","action":"EXPORT_DATA","resource":"customers-db","destination":"EXTERNAL_API","recordsAffected":20}`	REVIEW

Try this template on your own agents, in monitor mode first.

Use in Vulnify

Not legal advice. These templates are starting points to help you design internal controls for AI agents. They are not legal advice and do not make your organization compliant with LGPD, GDPR, HIPAA or any other law or regulation. Review them with your own legal and compliance team before relying on them. Templates are provided “as is”, without warranty. Whether a rule matches depends on how you classify your resources and on the data your agents send; test in monitor mode before enforcing.

License: the templates are dedicated to the public domain under CC0 1.0. “Vulnify” is a trademark; the CC0 dedication does not cover the Vulnify name or logo.