The Start Of Something New? New Jersey's Proposed Privacy Rules

On June 2, 2025, the New Jersey Office of Consumer Protection announced proposed rules for New Jersey's comprehensive consumer privacy law, the New Jersey Data Privacy Act (NJDPA), which went into effect on January 16, 2025.

While the proposed rules draw from the California and Colorado privacy regulations, they also would introduce a number of significant definitions and compliance mandates not found in the NJDPA or most other states.

Below are several key provisions in the proposed rules.

Definition of "Personal Data"

The NJDPA defines "personal data" as any information "linked or reasonably linkable to an identified or identifiable person," excluding de-identified data or publicly available information. The proposed rules incorporate that common standard but potentially expand it by listing the following data elements, which, when combined with other data, may render information "reasonably linkable":