Multistate Privacy Enforcement Sweep Puts Global Privacy Control In The Spotlight

Recent enforcement actions and announcements from the California Privacy Protection Agency (CPPA) and state Attorneys-General (AGs) in California, Colorado and Connecticut, and a California bill that passed the state legislature, signal a new phase of heightened enforcement, focused on honoring consumers' opt out requests, including through cookie banners and the Global Privacy Control (GPC).

Two critical developments stand out from our review of these actions and announcements: a crackdown on non-functional opt-out tools, highlighted by a multi-million dollar settlement and a multi-state investigative sweep; and a renewed emphasis on mandatory risk assessments for data "selling" and "sharing," including for online advertising practices that are commonplace.