On March 10, 2020, Vermont Attorney General T.J. Donovan
initiated an enforcement action based on Vermont's new data
broker law against Clearview AI, Inc.
Vermont's data broker law, which became effective January 1,
2019, governs data brokers, which it defines as companies that
collect and sell or license to third parties the personal
information of a consumer with whom the business does not have a
direct relationship. The law requires that data brokers (a)
annually register with the Vermont Secretary of State, including
completing certain necessary disclosures, and (b) maintain minimum
data security standards. The law also prohibits any businesses or
individuals – not just data brokers – from acquiring
brokered personal information through fraudulent means or for the
purpose of stalking, harassment, discrimination, or fraud.