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ARTICLE · 27 MAY 2025

State Comprehensive Privacy Law Update – May 19, 2025

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While most state legislatures are wrapping up their legislative sessions with little fanfare, Massachusetts appears to just be getting started.

United StatesPrivacy

While most state legislatures are wrapping up their legislative sessions with little fanfare, Massachusetts appears to just be getting started. On May 12, 2025, the Bay State introduced the Massachusetts Data Privacy Act (S 2516), a 70-page bill that combined provisions from bills previously introduced this session (S 29, S 45, and S 33) along with new requirements and language. This bill covers a lot of ground. It applies to all businesses that collect or process the personal data of 25,000 or more Massachusetts consumers or derive "valuable consideration" from the sale of personal data (without any thresholds for the value of revenue or consideration), effectively bringing all data brokers that process Massachusetts consumer data into scope. S. 2516 also introduces a broad definition of "sensitive data" that includes an individual's driving behavior and browsing data collected by cookies and other web tracking technology. It requires separate privacy policies

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