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CT AG Tong Advises on Connecticut Data Privacy Act Rights

Covered businesses under the Connecticut Data Privacy ActJuly 1, 2023Connecticut Attorney General

Summary

Attorney General William Tong released guidance advising Connecticut consumers of new privacy rights under the Connecticut Data Privacy Act (CTDPA), effective July 1, 2023. The CTDPA grants consumers rights to access, correct, delete, and opt-out of the sale of personal data and targeted advertising. Businesses must comply with these requirements, obtain consent for sensitive data and children's data, and maintain privacy notices.

Contract Impact

In-house legal teams should review vendor contracts (especially data processing agreements), customer agreements (terms of service and privacy policies), and any agreements involving the processing of personal data. Key clauses to examine include those addressing data subject rights (access, correction, deletion), consent mechanisms for sensitive and children's data, opt-out rights for the sale of personal data and targeted advertising, privacy notice content and delivery, data security measures, data retention periods, and breach notification procedures. Updates may be needed to ensure contracts require processors to assist with consumer rights requests, obtain verifiable consent for sensitive/children's data, provide clear opt-out methods, include audit rights for compliance, and align data handling practices with CTDPA requirements.

Contract Search Terms

opt-out mechanism for targeted advertisingsensitive data consent clausechildren's data consent provisiondata subject access request proceduredata deletion request processprivacy notice disclosure requirementsdata processing addendumdata retention schedulebreach notification clausedata sharing agreement

Laws Cited

Connecticut Data Privacy ActHealth Insurance Accountability and Portability Act of 1996

Violation Types

Entity Details

Entity

Covered businesses under the Connecticut Data Privacy Act

Also known as: Connecticut

Industry

Technology

Official Sources

Related Enforcement Actions

CT

SunRun, Inc.

$500K

Connecticut Attorney General William Tong announced settlements with SunRun, Inc., Elevate Solar Solutions, and two salespeople over allegations of deceptive solar sales, including impersonating consumers and locking homeowners into long-term contracts without consent. SunRun must pay $300,000 and provide consumer relief; Elevate and the salespeople face a stated $200,000 penalty, with $100,000 suspended subject to ongoing compliance.

CT

Mylan

$8.0M

Connecticut announced an $8 million settlement with Mylan over allegations that it used agreements to delay generic EpiPen competitors and took other actions that inflated prices. Mylan also agreed to provide 10,000 free EpiPens; the release states that Mylan denies wrongdoing.

CT

U.S. Department of Homeland Security

Connecticut Attorney General William Tong joined a coalition of 22 attorneys general in filing an amicus brief challenging DHS’s policy and practice of conducting warrantless civil immigration arrests. The press release describes a court challenge, not a privacy enforcement action or monetary penalty.

CT

Frontier Communications Parent Inc.

$625K

Connecticut reached a $625,000 settlement with Frontier Communications Parent Inc. over an April 2024 breach in which compromised employee and vendor credentials were used to access internal systems and exfiltrate unencrypted personal information of 58,841 Connecticut residents. The settlement requires Frontier to strengthen its security program, implement specific safeguards and training, and obtain an independent third-party assessment.

CT

Boston Children’s Health Physicians and XTIUM

$2.6M

Connecticut and New York found that Boston Children’s Health Physicians and its security vendor, XTIUM, failed to use reasonable safeguards, resulting in hackers accessing sensitive personal, medical, and employee information. The companies agreed to pay penalties totaling $2.64 million and implement enhanced cybersecurity measures.

CT

Character Technologies, Inc.

Connecticut joined a coalition of state attorneys general filing a notice in Character Technologies, Inc.’s bankruptcy proceedings, raising concerns about the company’s safety and privacy practices and the sensitive information it holds. The states seek protections for children and consumers if the company’s business or assets are sold or transferred; the filing does not impose a fine or other remedy.