The U.S. Department of Justice (DOJ) “Data Security Program” (DSP), also known as the “Sensitive Data Rule” or “Bulk Data Rule,” has prompted numerous questions about its scope and application. 

California’s legislature has once again taken center stage in the national privacy conversation, passing a flurry of privacy bills during a marathon session that stretched into the night of September 12. 

With 2025 more than half over and many state legislatures adjourned for the year, we look back at significant legislative developments concerning state comprehensive consumer privacy laws. 

In May 2025, Montana enacted Senate Bill 163 (SB 163), amending that state’s Genetic Information Privacy Act (MGIPA) to include protections for neurotechnology data—namely, data collected from the activity of the central or peripheral nervous system.

This year saw significant enforcement activity from the Federal Trade Commission on privacy, data security, and related technology topics, particularly with respect to location information, health, and other sensitive data; data brokers; children’s privacy and online safety; and consumer protection issues related to artificial intelligence. State-level privacy enforcers, such as those in T

U.S. privacy law continued to expand in 2024, both geographically and substantively.  We now have 19 states with comprehensive consumer privacy laws (some of which are already in effect, while others become effective in 2025 and 2026). This recap focuses on the 10 state laws that were enacted or took effect this year, as well as the states that enacted meaningful updates.

Continued cyberthreats drove expanded data security and breach notification requirements in 2024. Although sectors deemed high-risk saw significant activity, we also saw proposed regulations that stand to have a significant impact on a wide swath of private companies in the year to come.

This Update outlines highlights of data security law in 2024.