Alysa Hutnik Speaks to IAPP on Privacy Compliance Considerations Regarding Vermont’s Comprehensive Privacy Bill

Kelley Drye Partner Alysa Hutnik was quoted in IAPP’s article ​“PRA Highlights Novelties in Vermont’s Comprehensive Privacy Bill.” The bill carries data minimization standards resembling those found in Maryland’s comprehensive law, explicit protections on children’s and consumer health data, required user opt-out mechanisms, and required data protection assessments.

Hutnik found how the interplay between Vermont’s proposed requirements for targeted advertising and pseudonymous data arguably raises positive compliance considerations with the use of first-party data.

“There is potential circular logic when those two concepts are put together,” She said. ​“In a more practical sense, however, this could mean that targeted advertising is defined broadly to include some first party data monetization concepts that are growing in popularity, but opt-out rights may not need to be applied to such practices if pseudonymous data is being used and personal data to support those use cases is not being disclosed in a way that conflicts with the law.”

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