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State Privacy Action Grows: Consortium Expands, California Launches Data Broker Strike Force

By Liisa Thomas, Kathryn Smith & Angela Banks* on November 24, 2025
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The Consortium of Privacy Regulators is growing. Meanwhile, CalPrivacy has announced a new program, a data broker “strike force.”

Minnesota and New Hampshire have joined with Colorado, Connecticut, Delaware, Indiana, New Jersey, Oregon, and the California Privacy regulatory body (CalPrivacy) to coordinate on their enforcement of “comprehensive” privacy laws. The consortium was created earlier this year, with the stated goal of coordinating privacy law enforcement efforts. Since the consortium was created, California, Colorado and Connecticut joined together in September to investigate companies’ alleged failure to honor sale opt-out requests and honor GPC signals.

Meanwhile, CalPrivacy announced that it will increase its oversight of data brokers. It has created a special team called the Data Broker Enforcement Strike Force. This team will ensure that companies are following rules about protecting consumer privacy and registering as data brokers. The strike force will have more resources to investigate violations. The strike force creation follows recent actions brought by the agency under California’s Delete Act.

Putting it into Practice: The state-level actions are a reminder to those operating in the US. As we enter into 2026, expect more state level coordination and enforcement. This is a good time to assess if your privacy program takes an adaptive and principles-based approach. Do your training efforts go beyond memorization? Do you reward “small wins” and otherwise take an organizational change lens to your compliance efforts?

Photo of Liisa Thomas Liisa Thomas

Liisa Thomas, a partner based in the Chicago and London offices, is Leader of the firm’s Privacy and Cybersecurity Practice Group.

Read more about Liisa ThomasEmail
Photo of Kathryn Smith Kathryn Smith

Kathryn (“Katie”) Smith is an associate in the Intellectual Property Practice Group in the firm’s Chicago office and a member of the Privacy and Cybersecurity Team. She is certified by the International Association of Privacy Professionals (IAPP) for CIPP/US.

Read more about Kathryn SmithEmail
Photo of Angela Banks* Angela Banks*

Angela Banks is a Cybersecurity & Privacy Fellow in the firm’s Chicago office. 

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  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    Eye On Privacy
  • Organization:
    Sheppard, Mullin, Richter & Hampton LLP
  • Article: View Original Source

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