New comprehensive privacy frameworks in California, Virginia and Colorado are set to come into effect in 2023, and in recent days attention has turned to Utah, where a privacy bill closely resembling Virginia’s is on the governor’s desk for signature. The rulemaking processes for the enacted laws are in their early stages. To the chagrin of covered businesses, privacy advocates and interested spectators alike, it is too soon to tell what regulations will be promulgated and how the laws will be implemented and enforced. However, the relevant state organizations—which include newly created agencies, state Attorneys General (“AGs”) and so-called “Work Groups”—have made early progress and are signaling what we may see in the future. This Legal Update provides an overview of recent developments for each of the new laws.

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