As a reminder for business in Tennessee, the Tennessee Information Protection Act (TIPA) takes effect on July 1, 2025. This privacy law applies to for-profit businesses that:
- Operate in Tennessee or target Tennessee residents,
- Generate over $25 million in annual revenue, and
- Either:
- Process personal data of 175,000+ Tennessee residents, or
- Process data of 25,000+ residents and derive 50%+ of revenue from selling personal data.
Important Considerations for Business:
- Employment data is exempt: TIPA does not apply to data collected from employees, job applicants, or independent contractors.
- Consumer rights: include access, correction, deletion, data portability, and the ability to opt out of data sales, targeted advertising, and certain profiling.
- Privacy notices: must clearly explain data practices, consumer rights, and contact information.
- Data protection assessments: these are required for high-risk processing activities, including targeted advertising and managing sensitive data.
- No private lawsuits: Only the Tennessee Attorney General can enforce the law.
- Penalties: can reach up to $7,500 per violation, with a 60-day cure period.
- Safe harbor: Businesses that adopt a privacy program aligned with the NIST Privacy Framework may qualify for legal protection.
- TIPA does not require universal opt-out mechanisms.
For additional information:
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