Data Brokers

More Companies Are in Scope for State Data Broker Laws 

By Sam Castic

New and amended data broker laws make more companies that collect and disclose personal data subject to state data broker laws.  Last week New Jersey enacted a unique new data broker and data collector law, and Connecticut enacted (and then amended) one last month.  With Vermont's recent expansion of its law, and California regulation changes that took effect this year, there are some emerging scope expansions for these laws that all companies that collect and disclose personal data should be aware of. 

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What is Government-Related Data Under the DOJ Rule?

What is Government-Related Data Under the DOJ Rule?

By Hansenard Piou and Sam Castic

This is the third in a series of blog postsabout the DOJ Rule regarding Access To U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons(the “DOJ Rule”). It provides an overview of the second type of data that the DOJ Rule focuses on: government-related data.

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California Further Amends its Data Broker Registration Law

California Further Amends its Data Broker Registration Law

By Hansenard Piou

On October 8, 2025, Governor Gavin Newsom signed SB 361 into law. Introduced by Senator Josh Becker, the bill amends California’s Data Broker Registration Law (and amendments to the law under the Delete Act) with additional disclosure requirements for data brokers.

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Takeaways From the New DOJ Guidance on Its Cross-Border Data Rule

Takeaways From the New DOJ Guidance on Its Cross-Border Data Rule

By Sam Castic

On Friday April 11, 2025, the DOJ released a Compliance Guide and more than 100 FAQs on the Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons Rule (the “DOJ Rule”).  It also released an Implementation and Enforcement Policy, which indicates it will not prioritize enforcement against companies making good faith efforts to comply until July 8, 2025. 

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