Data Protection and Secure IT Asset Disposal under Brazil’s LGPD

For global companies operating in Brazil, it is no longer enough to protect personal data only while systems are in production. The way obsolete laptops, desktops, servers and storage devices are decommissioned and disposed of is also part of the data-protection story.

Under Brazil’s data protection law (LGPD), organizations remain responsible for personal data until it is effectively erased or rendered irreversibly inaccessible – including at the end of the hardware lifecycle. If discarded IT equipment still contains readable data, a breach or incident can easily be traced back to the company.

This guide explains how to align IT asset disposal with LGPD and corporate security requirements, and how Ecobraz supports secure, certified end-of-life management for IT equipment and electronic waste in Brazil.

1. Why end-of-life IT equipment is a data-protection risk

Almost every corporate IT asset stores some form of personal or sensitive information:

• Laptops and desktops with emails, files, browsing data and application caches;
• Servers and storage systems with customer, employee or patient databases;
• Network equipment with logs and configuration details;
• Mobile devices with apps, messages and offline data;
• Multifunction printers with internal queues and stored documents.

If these devices are removed from service but not properly sanitized or destroyed, the company’s exposure does not disappear. On the contrary, it becomes harder to control and monitor.

2. LGPD: what matters at the disposal stage

Some key concepts from LGPD that directly affect IT disposal include:

• Security: adopting technical and administrative measures to protect personal data;
• Prevention: taking steps to avoid incidents and damage to data subjects;
• Deletion: eliminating data once the purpose and legal basis no longer apply;
• Accountability: being able to demonstrate the effectiveness of protection measures.

In practice, organizations must be able to answer questions such as:

• How are IT assets decommissioned at the end of their lifecycle?
• What methods are used to erase or destroy data, and when?
• Which suppliers handle devices containing personal data?
• What evidence exists to show that disposal is secure and controlled?

3. Typical mistakes in IT asset disposal

Common patterns in corporate environments include:

• “Formatted” laptops donated or sold without secure wiping;
• Servers and drives sent to unregulated scrap dealers;
• Equipment auctioned off with intact storage media;
• Obsolete devices stored indefinitely in closets or warehouses, still containing data.

From a risk perspective, these scenarios all share one issue: the company has lost control of data-bearing devices without clear evidence of secure data destruction.

4. Internal policy for IT decommissioning

A solid approach starts with a clear IT asset end-of-life policy, integrated with privacy and information-security governance. At a minimum, it should define:

• Scope (which types of IT equipment are covered);
• Roles and responsibilities (IT, Security, ESG, Facilities, Procurement);
• Decommissioning workflow (logical shutdown, removal from directories and management tools);
• Rules for data sanitization and physical destruction, depending on asset criticality;
• Criteria for selecting specialized partners such as Ecobraz;
• Document retention rules for disposal records and certificates.

5. Data destruction methods: choosing a realistic model

An organization does not need a single universal method for all scenarios, but it does need a consistent and documented model:

• Logical wiping: appropriate when equipment will be reused in a controlled context, and when processes are standardized and auditable;
• Full-disk encryption: reduces risk during the asset lifecycle, but must be combined with clear end-of-life procedures;
• Physical destruction of media: strongly recommended when equipment leaves the company’s control or when risk is high.

Whichever methods are adopted, they must be applied systematically and recorded in a way that can be demonstrated to auditors and regulators.

6. Documentation that links LGPD, IT and e-waste

To show that LGPD requirements are being addressed at the disposal stage, organizations should maintain at least:

• Inventories of IT assets taken out of service, including disposal decisions;
• Records of approvals and change requests for decommissioning and disposal;
• Data-destruction certificates from Ecobraz, linked to specific batches or projects;
• Final destination certificates for electronic waste;
• Consolidated reports by legal entity and period;
• Contract clauses addressing confidentiality and data protection obligations of suppliers.

7. How Ecobraz supports secure IT disposal

Ecobraz operates as a specialized partner for electronic waste in Brazil, integrating environmental compliance, data security and social impact. For IT and security leaders, this translates into:

• Planned collection of IT equipment from offices, plants, data centers and public entities;
• Specific handling procedures for data-bearing devices;
• Secure data-destruction services, with certificates suitable for LGPD and audit files;
• Certified recycling and appropriate environmental treatment for all electronic waste;
• Complete documentation to support ESG, compliance and security reporting;
• Integration of reusable equipment into digital inclusion projects within the Ecobraz ecosystem, when compatible with security requirements.

8. LGPD-oriented checklist for IT asset disposal

• [ ] Is there a documented IT asset end-of-life policy covering Brazil?
• [ ] Are decommissioning workflows aligned with privacy and security teams?
• [ ] Are high-risk assets consistently subjected to physical media destruction?
• [ ] Are Ecobraz or other partners contractually bound to protect data and issue certificates?
• [ ] Are disposal and destruction records stored in a way that is easy to present during audits?
• [ ] Are ESG and privacy teams using Ecobraz data in their reports?

9. Turning secure disposal into a governance asset

End-of-life IT disposal is not just an operational concern. Done correctly, it becomes proof that the company manages the full lifecycle of personal data and IT assets, from onboarding to decommissioning.

By combining internal policies with Ecobraz’s certified services, organizations can reduce legal and security risks, support LGPD compliance and demonstrate a concrete link between data protection and environmental responsibility.

To explore secure and certified IT asset disposal for your Brazilian operations, visit https://ecobraz.org.