backBrazil’s National Data Protection Authority has issued Technical Note No. 1/2026/FIS/CGF/ANPD concerning the generative AI system Grok, integrated into the X platform, following complaints alleging the creation and manipulation of sexualised synthetic content, including material involving children and adolescents, without effective safeguards for consent, age verification or legitimate purpose. The document analyses the applicability of the Brazilian General Data Protection Law to AI-generated images, videos and audio referring to identified or identifiable individuals.
From a regulatory standpoint, ANPD clarifies that synthetic outputs may qualify as personal data and, depending on the circumstances, as sensitive personal data, thereby triggering stricter legal requirements under the LGPD. The authority reports internal testing indicating the possibility of manipulating real photographs to produce sexualised content and identifies potential shortcomings in the mitigation measures described by the company. The Technical Note concludes by proposing the opening of a dedicated supervisory proceeding and the assessment of measures aimed at preventing the generation of sexualised representations of children and adolescents, as well as of identifiable adults without proper authorisation, across all versions of the Grok model.
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