Personal Data Protection in the Financial Sector: accountability as a bridge between innovation, competition, and consumer protection

Abstract

The paper examines the centrality of the accountability principle in Brazil’s General Data Protection Law (LGPD) and its role in safeguarding human dignity. A deductive method is adopted, based on national and
international literature review, relating the four standards proposed by Daniel Sarmento – intrinsic value, autonomy, existential minimum, and recognition – to the LGPD’s material and procedural requirements. The study identifies accountability as an operational governance axis that reduces information asymmetries,
disciplines economic incentives, and structures transparency, particularly in the financial sector. It demonstrates that instruments such as records of processing, DPIA, legitimate-interest tests, and the data protection officer’s role make the technical and commercial choices of data controllers and processors auditable. The study concludes that accountability is the central governance axis of the LGPD, acting as a balancer that reduces information asymmetries, structures transparency, and disciplines economic incentives, especially in the financial sector. It is therefore argued that the fundamental right to data protection is not absolute and allows flexibility when a proper legal basis, proportionality, and accessible data-subject controls are ensured. Finally, it sustains that
regulatory convergence among the National Data Protection Authority (ANPD), the Banco Central do Brasil (BCB), and the Administrative Council for Economic Defense (CADE) reinforces predictability and legal certainty, converting dignity into an operational benchmark for a data-driven economy.