HR Internal Investigations 2026

BRAZIL Trends and Developments Contributed by: Patricia Barboza, Alinne Gordilho and Amanda Costa, CGM Advogados

Convergence of Trends: An Integrated Model for Secure and Efficient Internal Investigations When prevention and privacy meet, a new paradigm for internal investigations is born. At first glance, the prevention of psychosocial risks and the protection of personal data seem to address different realities: one focused on the mental health and well-being of workers, the other on privacy and information security. However, both share an essential point: the need to conduct internal investigations in an ethical, transpar - ent, and balanced manner, ensuring that the pursuit of efficiency does not compromise fundamental rights. The common thread between these two fronts is com - prehensive protection. This means ensuring the dignity of the individual, whether by avoiding practices such as harassment and psychological violence, or by preventing the mis - use of personal data. It also involves strengthening organisational trust, as investigations conducted in accordance with labour and regulatory rules increase the company’s credibility. In addition, practices that reconcile mental health and privacy reinforce social and environmental commitments, aligning with gov - ernance and ESG guidelines. Integrating these areas, however, is not simple. Regu - latory complexity requires clear protocols and mul - tidisciplinary teams to reconcile the requirements of NR-1 and LGPD, for example. The use of technology, although an ally in prevention and analysis, carries risks such as algorithmic biases and information leaks. Added to this is the cultural challenge: investigations must not be perceived as instruments of excessive surveillance, which could undermine internal trust. To address these obstacles, some strategic recom - mendations are essential. It is necessary to create unified policies that integrate occupational health, compliance, and data protection,

in addition to establishing interdisciplinary committees involving areas such as HR, legal, compliance, and IT. The adoption of ethical technology is another critical point, ensuring audited tools with algorithmic explain - ability and robust security. Finally, transparent communication with employees about the objectives, limits, and guarantees of inves - tigations is essential to maintaining trust. Looking ahead, companies that manage to align these two fronts will be better prepared to face emerging risks and meet regulatory requirements. The trend is for internal investigations to cease to be merely a corrective mechanism and become estab - lished as a strategic pillar, capable of promoting healthy, safe and reliable work environments. Conclusion Internal investigations are moving away from being a purely corrective resource to becoming an essential pillar of corporate governance. In 2026, two regulatory and cultural forces will shape this scenario: the need to prevent and remedy psy - chosocial risks, driven by the requirements of NR-1 of the MTE, and the obligation to ensure compliance with the LGPD in view of the increasing use of technology in investigations. These trends, although distinct, converge towards the same goal: protecting employees in the work - place and data, preserving organisational trust and the integrity of operations. Companies that manage to integrate these fronts (mental health and privacy) will be better prepared to face emerging risks, meet social expectations, and strictly comply with legal rules. The challenge is clear: how to conduct internal inves - tigations that are agile, ethical, and secure, without compromising fundamental rights? The answer lies in robust policies, audited technology, trained teams, and a corporate culture based on transparency and respect.

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