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CT AG Tong Announces CTDPA Global Opt-Out Requirement for 2025

Businesses subject to CTDPAJanuary 1, 2025Connecticut Attorney General

Summary

Attorney General William Tong announced that starting January 1, 2025, businesses covered by the Connecticut Data Privacy Act must honor global opt-out preference signals, allowing consumers to opt out of targeted advertising and data sales via tools like Global Privacy Control. The advisory explains requirements, notes exemptions for HIPAA-covered entities, and provides resources for compliance.

Contract Impact

In-house legal teams should review all vendor, customer, and data processing agreements where Connecticut residents' personal data is processed. Specifically, examine clauses governing data sharing, targeted advertising, data sales, and consumer consent mechanisms. Agreements must be updated to ensure they honor valid global opt-out preference signals (like GPC) as of January 1, 2025. Verify that contracts clearly define roles (controller vs. processor) under the CTDPA and incorporate necessary technical capabilities to recognize and process these signals. For entities handling health data, ensure contracts properly leverage the HIPAA exemption and do not inadvertently subject protected health information to CTDPA's opt-out requirements.

Contract Search Terms

global opt-out preference signalGlobal Privacy Control (GPC)opt-out mechanismtargeted advertisingdata saledata processing addendumdata sharing agreementconsumer consentprivacy policyHIPAA exemption

Laws Cited

Connecticut Data Privacy ActHealth Insurance Portability and Accountability Act of 1996

Violation Types

Entity Details

Entity

Businesses subject to CTDPA

Also known as: N/A

Industry

Technology

Official Sources

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