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Warning LetterLow Risk

Texas AG Notifies Over 100 Data Brokers of Apparent Noncompliance with Texas Data Broker Law

Multiple Unnamed Data Broker CompaniesJune 18, 2024Texas Attorney General

Summary

Texas Attorney General Ken Paxton issued warning letters to over 100 companies informing them of their apparent failure to register as data brokers with the Texas Secretary of State by the March 1, 2024 deadline required by Chapter 509 of the Texas Business and Commerce Code. The notification follows the establishment of a specialized privacy enforcement team within the AG’s Consumer Protection Division to enforce Texas privacy laws. The letters alert companies to potential penalties for noncompliance with registration and data safeguard requirements under Texas’s Data Broker Law.

Remedy

The notified companies are required to cure their noncompliance by registering as data brokers with the Texas Secretary of State and implementing required data safeguards to avoid statutory penalties for violation of Texas’s Data Broker Law. No monetary penalties or other formal remedies have been imposed as of the date of the warning letters.

Corrective Notice

Contract Impact

In-house legal teams should review all vendor agreements with entities that buy, sell, trade, or process consumer personal data to confirm whether such vendors are required to register as data brokers under Texas law. Teams should add clauses requiring vendors to certify compliance with Texas Data Broker Law registration requirements, implement adequate data safeguards, and notify the company immediately of any enforcement actions or noncompliance notices from the Texas Attorney General. Additionally, contracts should include audit rights to verify vendor registration status and data security practices, as well as indemnification clauses for penalties arising from vendor noncompliance with Texas privacy laws.

Contract Search Terms

data broker registrationTexas Data Broker LawChapter 509 Texas Business and Commerce Codepersonal data processingdata safeguard requirementsTexas Secretary of State data broker filingconsumer personal data

Laws Cited

Chapter 509 of the Texas Business and Commerce CodeTexas Data Broker Law
Tex. Bus. & Com. Code Chapter 509

Violation Types

Entity Details

Entity

Multiple Unnamed Data Broker Companies

Industry

Data Broker

Official Sources

Source Evidence

Entity Name
"over one hundred companies"
Laws Cited
"Chapter 509 of the Texas Business and Commerce Code"
Laws Cited
"Texas’s newly enacted Data Broker Law"
Violation Types
"apparent failure to register as data brokers with the Texas Secretary of State as required by Texas’s newly enacted Data Broker Law"
Event Type
"issued letters notifying over one hundred companies of their apparent failure to comply"
Jurisdiction
"Texas Attorney General Ken Paxton"

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