A recent settlement with an education service provider and three states – California, Connecticut, and New York – serves as a reminder to deactivate the credentials of departed employees. The case arose following a data breach suffered by Illuminate Education, which provides assessment software to K-12 school systems. As part of its services, the company stores sensitive details like students’ special education and accommodation needs.Continue Reading The Ghost of Employees Past: The Data Breach Risks from User-Credential Management

Can we take any insights from Connecticut’s first settlement under the state’s Data Privacy Act, reached with TicketNetwork, an online ticket marketplace? The AG concerns mirrored priorities outlined in Connecticut’s 2025 CTDPA Enforcement Report. This suggests that future cases may also draw from that report.Continue Reading Privacy Compliance Insights from Connecticut’s First Privacy Law Settlement

Connecticut has revised its privacy law for the third time since it was passed in 2022. With SB 1295, the state has mirrored others (like Colorado and Montana) in making ongoing changes to its law. Many of the changes incorporate either in concept, or wholesale, provisions that exist in other states. Connecticut makes these changes following 2024 and 2025 AG reports, which reports included recommendations to lawmakers, some of which ended up in SB 1295. Continue Reading Connecticut, the Provisions State, Adds New Provisions to its Privacy Law

The California Privacy Protection Agency announced this month that it, along with six other states, will be forming a new group called the “Consortium of Privacy Regulators.” (The other states are Colorado, Connecticut, Delaware, Indiana, New Jersey, and Oregon.) Members include the Attorneys General from these states, as well as California’s privacy regulator (the CPPA).Continue Reading New Era of Collaboration? States Team Up to Coordinate on Privacy Laws

When thinking about privacy notice obligations, companies often -incorrectly- leap to the wording in their privacy policies. The new comprehensive state privacy laws are a reminder that notice obligations are a bit broader than mere privacy policies. To the extent that these laws apply to your organization (see our prior applicability post) there are some notice-related obligations to keep in mind.Continue Reading The Comprehensive Privacy Law Deluge: Approaching Notice Obligations

Of the many worries on privacy compliance teams’ lists as we face the onslaught of state “general” privacy laws are the impacts they have on vendor contracts. Fortunately for those who have already had to deal with contracts with vendors (service providers, processors) in California or EU’s GDPR, the impact should be fairly minimal.Continue Reading The Comprehensive Privacy Law Deluge: Updating Vendor Contracts

With a little less than a week before the next US state “comprehensive” privacy laws (Colorado and Connecticut) go into effect, many are reviewing existing practices. One that keeps coming up is the concept of “profiling.” As a reminder, we now have 11 states with comprehensive privacy laws: California, Colorado, Connecticut, Florida, Indiana, Iowa, Montana, Tennessee, Texas, Utah, and Virginia.Continue Reading The Comprehensive Privacy Law Deluge: What to Do About “Profiling”

The Connecticut governor recently signed SB 1103, bringing the state into the artificial intelligence regulation fray. The law regulates state agencies, and calls on the Department of Administrative Services to perform regular assessments of systems use by these agencies. The assessment is to identify which systems use artificial intelligence and to ensure that the use does not result in unlawful discrimination or disparate impacts. The systems inventory must be conducted by December 31 of this year, and the assessment by February 1, 2024. These inventories and assessments must thereafter be conducted on an annual basis.Continue Reading Connecticut Enters AI Fray