🔴 LGPD Compliance: Auditoria De Dados Sensíveis

Guys, let's talk about something super important for our systems: LGPD Compliance! Specifically, we need to implement an audit of sensitive actions to ensure we're following the law and protecting user data. This is crucial for our company's reputation and, of course, to avoid hefty fines. Let's dive in and see what's needed, how we'll do it, and why it's so critical. This article is your guide to ensuring your system meets LGPD requirements, covering everything from the legal basics to practical implementation steps. We'll explore the importance of auditing sensitive actions, the proposed solutions, and the acceptance criteria for a successful implementation. By the end, you'll have a clear understanding of the tasks at hand, the priorities, and the resources available to ensure our compliance with the LGPD.

⚖️ Requisito de Compliance LGPD

We need to get serious about LGPD compliance! This is not just a suggestion; it's a legal requirement. Let's break down the details:

• Severidade: 🟡 MÉDIA - This means it's a mandatory compliance. We've got to do it!
• Base Legal: LGPD Art. 37 - This article of the LGPD mandates that we keep a record of all data processing operations.
• Impacto: Multa de até 2% do faturamento (max R$ 50 milhões) - If we don't comply, we could face some serious financial penalties. Ouch!

Basically, the law is saying we have to keep track of what's happening with people's data. This includes who's changing it, when, what the old values were, and where the request came from (IP, user agent). It's all about being transparent and accountable. This ensures that we not only comply with the law but also build trust with our users, showing them that we take their data privacy seriously. By implementing these measures, we safeguard against potential data breaches and misuse, reinforcing our commitment to data protection. This level of diligence protects our company from legal liabilities and enhances our credibility in the eyes of regulatory bodies and the public.

📋 Descrição

The LGPD demands that we maintain a record of all data processing operations. Currently, our system is falling short in a few key areas. It's like we're missing crucial pieces of the puzzle.

• Who altered personal data? We need to know who is making changes.
• When did they alter it? Time stamps are essential.
• What was the previous value? Before and after comparisons are vital.
• Where did the request come from? (IP, user agent) This helps us track the source of the changes.

Essentially, our system needs to be able to tell the story of every data modification. This level of detail is critical for accountability. By tracking these data points, we can monitor and identify potential issues or malicious activities swiftly. The absence of this information creates a gap in our security posture, leaving us vulnerable to compliance violations and data breaches. Therefore, implementing this is vital for the protection of our users' data, ensuring regulatory adherence, and maintaining the integrity of our systems.

🎯 Ações Sensíveis Não Auditadas

Here's where things get interesting. We need to identify all the sensitive actions that need auditing. We've split this up into categories to make it easier to understand.

Dados Pessoais (LGPD Art. 5º, I)

These are actions related to personal data. Think of it as anything that can identify a person.

• [] Atualização de endereço de entrega - Updating the delivery address.
• [] Alteração de método de pagamento - Changing the payment method.
• [] Upload de prescrição médica (dado sensível de saúde!) - Uploading a medical prescription (super sensitive!).
• [] Mudança de plano de assinatura - Changing subscription plans.
• [] Atualização de preferências de entrega - Updating delivery preferences.

Dados Financeiros

Anything related to money needs extra care.

• [] Criação de cobrança - Creating a charge.
• [] Cancelamento de assinatura - Canceling a subscription.
• [] Reembolsos - Issuing refunds.

Acessos

Who's accessing what? This is key.

• [] Visualização de histórico de pagamentos - Viewing payment history.
• [] Download de faturas - Downloading invoices.
• [] Acesso a dados de terceiros (tentativas) - Attempts to access third-party data.

For each of these actions, we need to track the details. This is where the auditing comes in. The actions highlighted are critical points where data can be compromised or misused, making it imperative to implement robust audit trails. Properly auditing these sensitive areas helps us to quickly identify and respond to security incidents. This protects user data and ensures compliance with data protection laws. By monitoring these actions, we establish a robust security framework that minimizes risks and bolsters our ability to meet the stringent requirements of data privacy.

✅ Solução Proposta

So, how do we fix this? Here’s a detailed look at the solution we’re proposing to get us up to speed on LGPD compliance.

1. Criar Tabela de Auditoria

We need a dedicated table to store all the audit logs. Here's a look at the Prisma schema:

// prisma/schema.prisma
model AuditLog {
  id          String   @id @default(cuid())
  userId      String
  user        User     @relation(fields: [userId], references: [id])
  
  action      String   // UPDATE_SHIPPING_ADDRESS, UPLOAD_PRESCRIPTION, etc
  entityType  String   // Subscription, Payment, Prescription
  entityId    String
  
  oldValue    Json?    // Valor anterior (JSON)
  newValue    Json?    // Novo valor (JSON)
  
  ipAddress   String?
  userAgent   String?
  
  status      String   // SUCCESS, FAILED, BLOCKED
  errorMessage String?
  
  createdAt   DateTime @default(now())
  
  @@index([userId, createdAt])
  @@index([action, createdAt])
}

• AuditLog Model: This is the core of our solution. It defines what information we’ll store. We'll track the user, the action performed, the entity type, and the ID of the entity that was changed.
• userId: The user who made the change.
• action: A description of what happened (e.g., UPDATE_SHIPPING_ADDRESS).
• entityType: The type of data that was changed (e.g., Subscription, Payment).
• entityId: The ID of the specific item that was changed.
• oldValue and newValue: The before and after values of the change (stored as JSON).
• ipAddress and userAgent: The IP address and user agent of the request.
• status: Whether the action was successful, failed, or blocked.
• errorMessage: Any error messages that occurred.
• createdAt: Timestamp for when the change happened.

This setup provides a comprehensive record of all changes, enabling detailed analysis and robust auditing capabilities. This architecture is vital for our LGPD compliance efforts because it enables us to capture, store, and access the necessary information to prove compliance and respond effectively to data privacy inquiries.

2. Helper Function Centralizada

To make our lives easier (and less prone to errors), we'll create a centralized helper function.

// lib/audit-logger.ts
export async function logAudit({
  userId,
  action,
  entityType,
  entityId,
  oldValue,
  newValue,
  request,
  status = 'SUCCESS'
}: AuditLogParams) {
  return prisma.auditLog.create({
    data: {
      userId,
      action,
      entityType,
      entityId,
      oldValue: oldValue ? JSON.stringify(oldValue) : null,
      newValue: newValue ? JSON.stringify(newValue) : null,
      ipAddress: request.headers.get('x-forwarded-for') || 
                 request.headers.get('x-real-ip'),
      userAgent: request.headers.get('user-agent'),
      status,
      createdAt: new Date()
    }
  })
}

• logAudit Function: This function takes all the necessary information and saves it to the AuditLog table. It also retrieves the IP address and user agent from the request. This centralized helper streamlines the auditing process and makes it much easier to integrate auditing into our existing codebase. It allows us to track who made the change, what was changed, the previous and new values, and when it was changed. This functionality is essential for compliance with the LGPD.

3. Uso em APIs

Here’s how we'll use this in our APIs. Let's take an example.

// Exemplo: /api/assinante/subscription (PUT)
export async function PUT(request: NextRequest) {
  // ... autenticação ...
  
  // Buscar valor atual ANTES de atualizar
  const currentSubscription = await prisma.subscription.findUnique({
    where: { id: subscriptionId }
  })
  
  // Atualizar
  const updated = await prisma.subscription.update({
    where: { id: subscriptionId },
    data: { shippingAddress }
  })
  
  // AUDITAR a mudança
  await logAudit({
    userId: user.id,
    action: 'UPDATE_SHIPPING_ADDRESS',
    entityType: 'Subscription',
    entityId: subscriptionId,
    oldValue: currentSubscription.shippingAddress,
    newValue: shippingAddress,
    request,
    status: 'SUCCESS'
  })
  
  return NextResponse.json({ success: true })
}

• Example API Route: This code shows how to audit an update to a subscription's shipping address. Before updating the data, we fetch the current value. After the update, we call logAudit with all the relevant information. This ensures that every update is recorded, following a clear pattern of before and after states. This approach is key to our LGPD compliance because it provides a detailed, auditable record of all changes, ensuring accountability and transparency. This API example shows the practical application of our auditing strategy, demonstrating how we intend to secure our user’s data and keep a record of all modifications.

🎯 Critérios de Aceitação

To ensure we're on track, we need to meet these criteria.

• [] Tabela AuditLog criada no Prisma - The AuditLog table must be set up in Prisma.
• [] Helper logAudit() implementado - The logAudit() function should be working.
• [] 5 endpoints críticos com auditoria - We need to implement auditing in at least five critical endpoints.
  • /api/assinante/subscription (PUT)
  • /api/assinante/prescription (POST/DELETE)
  • /api/assinante/delivery-preferences (PUT)
  • /api/subscription/change-plan (POST)
  • /api/subscription/update-payment (POST)
• [] Testes unitários para logAudit() - We should have unit tests for the logAudit() function.
• [] Dashboard admin para consulta de logs - A basic admin dashboard to view the logs.
• [] Política de retenção (7 anos conforme LGPD) - We need to retain the logs for seven years, as required by the LGPD.

These criteria define the successful completion of the auditing implementation. This ensures all sensitive actions are thoroughly monitored and recorded. Meeting these criteria guarantees that we have a solid and legally sound approach to data protection.

⏱️ Estimativa

• Tempo: 8-10 horas - Here's a breakdown of the estimated time to complete the work.
  • Schema Prisma + migration: 1h - Setting up the database schema and migrations.
  • Helper function: 2h - Building the core helper function.
  • Implementação em 5 endpoints: 4h - Implementing the auditing in five endpoints.
  • Dashboard básico de consulta: 2h - Creating a basic dashboard for viewing the logs.
  • Testes: 1h - Writing unit tests.

📚 Referências

• LGPD Art. 37 - The relevant article of the LGPD.
• ANPD - Guia de Boas Práticas - Good practices guide from the National Data Protection Authority.
• ISO 27001:2013 - Audit log control - Relevant for controlling audit logs.
• Análise completa: SUBSCRIBER_AREA_ANALYSIS.md - Complete analysis document.

⚠️ Observação Importante

Prescrições médicas são dados sensíveis de saúde (LGPD Art. 5º, II). O upload e acesso a estes documentos DEVE ser auditado com rigor especial. - Medical prescriptions are sensitive health data (LGPD Art. 5th, II). Upload and access to these documents MUST be audited with special rigor. This requires extra care because this type of data is very sensitive. We need to be extra careful with these and apply more rigorous checks and monitoring. This includes stringent access controls, encryption, and regular audits to ensure their protection. This heightened level of care underscores our commitment to data privacy and security, as these measures minimize the risk of data breaches and misuse, fostering trust with our users and ensuring legal compliance. Implementing a robust audit trail for these sensitive actions helps to quickly identify and address any security incidents related to medical data.