Since Vermont became the first state to regulate data brokers comprehensively, numerous states have followed suit. Substantial, dedicated regulation now exists in California, New Jersey, Oregon, Texas, and Vermont. Enforcement is growing.
Companies whose services involve selling, trading, or otherwise providing data about individuals with whom they do not have a direct relationship should carefully consider the applicability of these laws.
If applicable, critical requirements that data brokers should have on their essential “to-do” list will likely need to include the following:
- Registration: California, New Jersey, Oregon, Texas and Vermont each contain formal registration requirements. In California and Texas, revenue or other thresholds may apply; in other states, no such threshold is required. Registration fees are required. For large data brokers, New Jersey’s requires notably large registration fees (annual registration fee of over $1,000,000 dollars if the broker sells or
