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This article analyzes the institutional grammar of data governance in Brazilian municipalities, focusing on the institutional designs that develop in local governments from emerging institutions. The article mapped 27 Brazilian municipalities with more than 500,000 inhabitants that regulated their strategies for implementing the rules included in the General Data Protection Law (LGPD). Using the Institutional Grammar Tool methodology, crossed with restrictiveness and entropy metrics, we analyzed the institutional statements in municipal decrees that define the strategy for implementing governance and data protection in Brazil. Based on the data analyzed, the article concludes that the result of LGPD implementation strategies is to produce institutional diversity that brings new risks to digital transformation projects in governments. The conclusion is that local government organizations tend to produce more restrictive governance solutions, with the potential to create barriers to innovation due to the entropy of regulated objects and stakeholders.
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Filgueiras et al. (2025) studied this question.
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