Announcing the July 31, 2025, effectiveness of Minnesota’s strict consumer privacy law (CPL), the Act’s author said in a press release that he will be personally making requests to a “long list of ‘data brokers’ … [to] provide a timely ‘test case’ that we can use to measure compliance….” Until January 31, 2026, businesses will have 30 days to cure violations.
We breakdown the details of Minnesota’s, and the other five new CPLs coming effective between July 1, 2025, and January 1, 2025, (as well as key amendments to other CPLs coming effective during that time), here. Minnesota sets a new high-water mark amongst the 20 state CPLs in the following ways:
- Similar to Oregon, the right to obtain a list of specific third parties to which personal data has been disclosed;
- Like upcoming California regulations, data inventory obligations;
- The requirement that controllers document and maintain written policies and procedures specific to CPL compliance (i.e., a formal information governance program), including the appointment of a Chief Privacy Officer or other executive with program oversight responsibility.
- The right to know the personal data assessed in, and question the basis of, profiling and automated decision-making, and what could have been done to result in a different decision, and to obtain reevaluation on corrected data (if applicable) and to opt-out of future profiling.
Like other high-water-mark states, Minnesota requires data processing risk assessments be conducted, documented and retained for inspection, and that browser opt-out signals be honored.
The Minnesota Attorney General has published FAQs and guidance for consumers and businesses (both controllers and processors) here.
Detailed tables comparing and contrasting key elements of the 20 state CPLs are available to clients and non-clients here, where the table of contents is available for perusal. An updated version of the tables will be released next week and subscribers are entitled to updates, which are published approximately every six months. This is unique and valuable resource to aid in managing the ever-changing patchwork of state CPLs.
For more information, contact the author or your Squire Patton Boggs relationship partner.
Disclaimer: While every effort has been made to ensure that the information contained in this article is accurate, neither its authors nor Squire Patton Boggs accepts responsibility for any errors or omissions. The content of this article is for general information only and is not intended to constitute or be relied upon as legal advice.