Data brokers are facing heightened scrutiny at the state level. Several states are continuing to expand their data broker registration frameworks, enact substantive restrictions on certain categories of data sales, and pursue enforcement proceedings against companies.

Companies that generate revenue by aggregating, selling, licensing, or otherwise monetizing consumer data – regardless of how those activities are labeled internally – should carefully assess whether they fall within the scope of applicable state data broker frameworks. Below, we identify recent data broker developments that companies should be monitoring.