Not necessarily. From a data protection perspective, the Brazilian General Data Protection Law ("LGPD") requires a legal basis for each processing activity. The data subject's consent is just one of the 10 available legal bases for data processing. Therefore, this should be assessed on a case-by-case basis, depending on the legal basis relevant for processing.

If no personal data is included, the LGPD provisions are not applicable.

From a banking perspective, since a cloud service provider will not have access to financial data, which will be encrypted in the cloud and the cloud service provider will not hold the encryption key, consent will not be required.