Digital Transformation and Data Protection in Brazil: An Institutional Analysis of the General Data Protection Law in State Capitals

Abstract

Introduction:  Digital transformation in Brazil’s public sector faces persistent challenges related to data governance, particularly following the enactment of the General Data Protection Law (Lei Geral de Proteção de Dados – LGPD, in Portuguese). This article examines how Brazilian state capitals have structured their data governance policies and the implications of these arrangements for the digital transformation of local governments. The analysis draws on the Institutional Analysis and Development (IAD) Framework to explore the institutional arrangements that shape the design and implementation of such policies. Materials and methods: The study adopted a qualitative approach, combining documentary analysis of municipal regulatory instruments with semi-structured interviews conducted with public managers, technical staff, and oversight body representatives involved in LGPD implementation across all 27 state capitals. Data analysis followed a thematic content approach, using the IAD framework as the guiding lens.  Results:  The implementation of the LGPD has incorporated new actors into local data governance, most notably internal and external oversight bodies. The strategies adopted across state capitals show significant heterogeneity, reflected in: (i) the lack of effective mechanisms for horizontal coordination; (ii) substantial differences in organizational arrangements; and (iii) limited standardization of tools and procedures. This fragmentation undermines policy effectiveness and constrains the development of integrated digital platforms for public service delivery. Discussion:Fragmented data governance and the absence of effective intergovernmental coordination represent structural barriers to the digital transformation of local governments in Brazil. These findings point to the need for more robust coordination mechanisms across levels of government, as well as the development of national guidelines to foster greater alignment in data governance practices.