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SettleADebt C_BR PASS-11 — Brazil

Two bounded corrections to reviewed PASS-07 positive-history research

Affected report: C_BR PASS-07, response 419e60ba-ee9c-46bc-b4f9-1b4dbae72d36 Scope: Only:

1. the omitted standing prior-information right in Lei 12.414/2011 art. 5(V); and
2. the PASS-07 source-count classification plus the exact receipt assumption in fictional workflow H06.

All other PASS-07 findings, source rows, claims, coverage rows, calculations, examples, read limits, unresolved questions and publication/currentness/private/local/foreign/A097/A098/country holds remain unchanged.

Fresh PASS-11 legal-source access: October 26, 2026 PDT / October 27, 2026 UTC. Exact per-source search/open clock times were not logged and remain unknown. No session window is inferred.

This is a correction overlay, not a whole PASS-07 rerun, new provider assessment, publication approval or independent review.

R1. Separate prior-information right

1.1 Exact operative provision

Current Lei 12.414/2011 art. 5(V) states that the cadastrado has the right:

“ser informado previamente sobre a identidade do gestor e sobre o armazenamento e o objetivo do tratamento dos dados pessoais”

Faithful English paraphrase:

To be informed beforehand about the identity of the database manager and about the storage and purpose of the processing of personal data.

Full official current compiled body:

https://www.planalto.gov.br/ccivil_03/_ato2011-2014/2011/lei/l12414.htm

Exact pinpoint: art. 5 caput, V. The present wording was introduced by Lei Complementar 166/2019 art. 2 and became effective under LC 166 art. 7(II), after 91 days from official publication. Planalto+1

Correction determination

C_BR-P11-C001 — A098. Lei 12.414 art. 5(V) creates a standing, separately expressed right of the cadastrado to receive prior information concerning:

• the identity of the gestor;
• the storage of the personal data; and
• the purpose of that personal-data processing.

This right was omitted from the PASS-07 opening discussion, access-rights summary and granular coverage.

1.2 Distinction from the other PASS-07 rules

The omitted right is not interchangeable with any of the following:

The current compiled statute displays all of those provisions as separate clauses. LC 166 likewise enacted the revised art. 4 framework and the revised art. 5(V) as separate amendments. Planalto+2

C_BR-P11-C002 — A098. The absence of a prior-opt-in requirement for opening does not mean that no prior privacy information is owed.

C_BR-P11-C003 — A098. The art. 4 §5 exception is textually limited to the post-opening communication described in art. 4 §4; it is not an express exception to art. 5(V).

C_BR-P11-C004 — A098. The prior specific authorization for full-history access under art. 4(IV)(b) and the art. 5(V) prior-information right have different functions and should not be merged into one consent rule.

C_BR-P11-C005 — A098. The 60-day consultant-access rule in art. 4 §7 does not itself determine whether, when or how art. 5(V) was satisfied.

1.3 Unresolved implementation question

Neither the current compiled Lei 12.414 provisions read here nor the operative portions of Decreto 9.936 reopened for this patch expressly settle:

• what exact event the word “previamente” in art. 5(V) must precede;
• whether the art. 4 §4 post-opening communication can also satisfy art. 5(V);
• what additional content would be required for one communication to perform both functions;
• how art. 5(V) operates when art. 4 §5 dispenses with the §4 communication because another positive record already exists; or
• which actor and evidence mechanism definitively proves compliance in each implementation model.

Decreto 9.936 art. 2(IV)(a) requires managers to provide channels allowing registered persons to exercise the rights in Lei 12.414 arts. 5 and 6, but the portions read do not supply an express sequencing rule equating art. 5(V) with the later art. 4 §4 notice. Planalto

C_BR-P11-C006 — A098. The exact sequencing and satisfaction relationship between art. 5(V) and art. 4 §§4–6 remains an implementation hold. PASS-11 does not decide that the 30-day communication automatically satisfies art. 5(V), nor does it create a renewed prior-consent requirement.

No actual manager, communication, opening, notice or person was examined; no breach conclusion follows.

Exact old-to-new affected-text crosswalk

Only the cells and paragraphs below receive a correction. All unaffected PASS-07 text remains preserved.

Crosswalk count: 10 affected items.

P07 granular coverage-cell correction

Only one original PASS-07 coverage cell is modified.

The PASS-07 granular-coverage row count remains unchanged. This is a qualification of an existing row, not a new P07 row.

Affected workflow qualifications

H01 — Automatic opening without prior opt-in

Preserved facts and calculations: Opening on October 5, 2026; no prior opt-in; existing 30-day and 60-day arithmetic remains exactly as reviewed.

Added qualification only:

• The absence of prior opt-in does not itself invalidate opening under art. 4(I).
• It also does not eliminate the registered person’s separate art. 5(V) right.
• H01 does not stipulate or prove that the person was previously informed of:the manager’s identity;the storage of personal data; orthe purpose of processing.
• H01 does not assume the later 30-day communication satisfies art. 5(V).
• No actual compliance or breach conclusion follows.

Claims: C_BR-P11-C001–C006. Primary source: Lei 12.414 arts. 4(I), 4 §§4–7 and 5(V), https://www.planalto.gov.br/ccivil_03/_ato2011-2014/2011/lei/l12414.htm. Planalto+1

H02 — Missing or delayed opening notice

Preserved facts and original branch: The example tests absence or delay of the art. 4 §4 communication and the possible existing-record exception in art. 4 §5.

Added qualification only:

• Art. 4 §5 dispenses with the communication described in art. 4 §4 when another positive record is already open.
• The provision does not expressly say that art. 5(V) is also dispensed with.
• A prior disclosure by another manager, a shared disclosure, or another communication may be relevant, but no such facts are stipulated.
• The exact legal relationship remains unresolved rather than being treated as a second consent requirement or automatic violation.

Claims: C_BR-P11-C001–C006. Primary source: same current compiled law, arts. 4 §§4–6 and 5(V). Planalto+1

H06 — Inaccurate partial-payment datum

Corrected stipulated trigger

For the reviewed calculation only, stipulate:

The relevant source receives the verification request on Friday, October 16, 2026.

Lei 12.414 art. 8(III) requires the source to verify and confirm or correct challenged information within no more than two business days whenever requested:

• by a database manager; or
• directly by the registered person.

Full official source:

https://www.planalto.gov.br/ccivil_03/_ato2011-2014/2011/lei/l12414.htm

Exact pinpoint: art. 8(III). Planalto

Preserved conditional count:

• Monday, October 19 = business day 1.
• Tuesday, October 20 = business day 2.

October 20 remains conditional upon:

• the source itself receiving the request on Friday, October 16;
• that Friday being the operative receipt date;
• no relevant receipt cutoff changing the date;
• no intervening holiday;
• and no disputed delivery or authentication issue.

A challenge made only to a manager, consultant, customer-service intermediary or another actor on Friday does not by itself fix the source’s art. 8(III) start date. If the source receives the request later:

source verification endpoint = actual source receipt date + 2 business days

No alternate calendar date is calculated here.

The following clocks remain distinct and are not recomputed:

• the art. 5(III) period of up to 10 days for correction or cancellation across databases sharing the erroneous information; and
• the art. 8(IV) period of up to 10 days for the source to update and correct information sent to managers. Planalto+1

C_BR-P11-C007 — A097. The art. 8(III) two-business-day source duty is triggered by a request reaching the source through one of the statutorily identified routes.

C_BR-P11-C008 — A098. H06’s October 20 endpoint is conditional on the stipulated October 16 source receipt; a challenge elsewhere does not automatically establish that source-receipt date.

C_BR-P11-C009 — A098. The two-business-day source-verification period, the 10-day cross-database correction period and the 10-day source update/correction period are separate statutory clocks.

R2. Corrected PASS-07 source-count audit

Replacement source-count paragraph

Corrected source audit: PASS-07 displayed 11 source rows. They divide into four operative/amending bodies (S001–S004), four limited crossover or timing sources (S007–S010), one historical revoked source (S011), and two index/unread dynamic bodies (S005–S006). Within the four limited crossover/timing rows, S007–S008 were fresh limited primary-family reads, while S009–S010 were precisely dated prior BR6 reuse rather than fresh PASS-07 reads. S004’s official consolidated Resolução 4.737 PDF was read and displayed Resolução 4.990 annotations, but that does not establish that the standalone S005 Resolução 4.990 body was read. Decreto 9.936 art. 22 confirms repeal of Decreto 7.829, but that current repeal provision does not retroactively convert S011’s historical body into a fresh PASS-11 read. Source-specific opening times remain unknown.

Decreto 9.936 art. 22 expressly revokes Decreto 7.829, while art. 23 makes Decreto 9.936 effective on publication. Planalto+1

All 11 original PASS-07 source rows

C_BR-P11-C010 — A098. The corrected PASS-07 partition is exactly 4 + 4 + 1 + 2 = 11.

C_BR-P11-C011 — A098. Reading the consolidated S004 PDF and its visible amendment annotations does not establish a substantive read of standalone S005.

C_BR-P11-C012 — A098. Reading the current repeal clause in Decreto 9.936 does not establish a new read of the repealed Decreto 7.829 body.

C_BR-P11-C013 — A098. S009 and S010 are dated reuse, not fresh PASS-07 legal-source access.

PASS-11 legal source register

No PASS-11 official source fetch failed. Consequently, no alternate-source retry was needed. P07 S005 and S006 remain prior index/unread rows and were deliberately not retried.

PASS-11 legal-source count: 3.

PASS-11 atomic correction-claim register

Atomic correction-claim count: 15.

Complete PASS-11 correction coverage

Core correction-coverage count: 20.

Retained holds

Retained-hold count: 8.

Reconciliation and counts

Final patch disposition

PASS-11 corrects two bounded defects:

1. PASS-07 omitted the distinct Lei 12.414 art. 5(V) prior-information right. The correction now makes clear that opening without prior opt-in is not the same thing as opening without prior privacy information, while leaving the exact interaction with the 30-day post-opening communication unresolved.
2. PASS-07’s source-count narrative is corrected to a coherent 11-row partition, and H06 now expressly assumes that the source itself received the verification request on Friday, October 16, 2026.

Nothing else in PASS-07 is modified or accepted by implication.

END C_BR PASS-11