Enforcing Privacy Through Collaboration: An Overview of the Consortium of Privacy Regulators' Approach
In the rapidly evolving digital landscape, the Consortium of Privacy Regulators (CPR) is playing a crucial role in shaping privacy enforcement across the United States. This multi-state partnership of government agencies, including regulators from California, Colorado, Connecticut, New Jersey, Oregon, Indiana, Delaware, and California's dedicated enforcement agency, the California Privacy Protection Agency (CPPA), is working together to enforce consumer privacy laws.
The Consortium's primary goal is to address the inconsistency in privacy enforcement caused by a patchwork of state laws. By coordinating investigations and aligning enforcement priorities, the Consortium is demonstrating what a more unified approach to privacy regulation could look like nationwide.
One of the key initiatives of the Consortium is the revision of Model #672 by the NAIC Privacy Protections Working Group. This revised model aims to enhance consumer rights, consent mechanisms, third-party obligations, and limits on the sale and disclosure of sensitive personal information. The full draft is expected for public comment by early 2026.
Meanwhile, state attorneys general (AGs) are increasingly specialized and empowered in privacy enforcement. Recent actions, such as Texas AG’s lawsuit over covert geolocation tracking and the California AG’s major CCPA settlement against Healthline Media for unauthorized sharing of sensitive health data, reflect a heightened enforcement vigor and expanding scope in protecting consumer privacy.
The Consortium's work on model laws supports and complements state-level enforcement by AGs, collectively increasing the effectiveness of privacy protections nationwide. However, the lack of a federal privacy standard poses significant challenges, as companies must navigate a growing patchwork of state laws, increasing both operational complexity and compliance costs.
The Consortium's real impact comes from its ability to enable states to conduct joint investigations, share tools and expertise, align on how privacy laws should be interpreted and enforced, and focus on protecting people from real harm. Companies that collect more personal data than necessary are now more likely to face regulatory questions and scrutiny.
In the realm of identity platforms, regulators are focusing on three key areas: storage and access controls, consent and transparency, and how companies explain their data practices. Decentralized identity systems, which keep information on the user's device or distribute it in secure, limited-use fragments, are gaining attention as they offer selective disclosure, allowing users to prove specific facts without providing full identification documents.
Regulators are also emphasizing data minimization, expecting companies to collect only the information necessary for a specific purpose and avoid holding on to it longer than needed. Sensitive information, such as website documents, biometrics, and other verification data, carries a higher risk and requires stronger justification.
In conclusion, the Consortium of Privacy Regulators is strengthening the privacy regulatory regimes in the United States by setting evolving model privacy standards that influence state enforcement strategies and legislation, while state AGs apply these laws in practice through more sophisticated and specialized enforcement efforts. This dual approach is essential in navigating the complexities of privacy protection in 2025.
- The work of the Consortium of Privacy Regulators (CPR) extends beyond model laws, influencing state enforcement strategies and legislation in areas like data minimization and decentralized identity systems, key aspects in personal-finance and data-and-cloud-computing technology.
- The Consortium's attempts to address the inconsistency in privacy enforcement caused by state laws has led to an increase in operational complexity and compliance costs for companies, a challenge that lies at the intersection of business, technology, and finance.
- As the Consortium and state attorneys general (AGs) work together to protect consumer privacy, they focus on critical areas such as the handling of sensitive personal information in the finance industry, demonstrating the importance of these efforts in the broader landscape of business and technology.
