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Consumer Reports Comments on Vermont H. 121 (Consumer Privacy Legislation)

Consumer Reports, supports, if amended, Vermont. H. 121. The measure would extend to Vermont consumers important new protections, including by providing the ability for consumers to opt out from targeted advertising, predictive analytics, tracking, or the sale of personal information through a universal opt out mechanism. H. 121 also includes a number of other elements that we generally support, including adding data broker registration, security breach notification, and opt out requirements, as well as biometric privacy protections.

However, the legislation still lacks a number of key definitions that could hinder its overall effectiveness. There are also several potential loopholes data collectors could exploit to evade the consumer protections envisaged by the bill. We offer several suggestions, based on our Model State Privacy Act, to strengthen the bill to provide the level of protection that Vermonters deserve.

  • Ensure targeted advertising, tracking, and predictive analytics are adequately covered
  • Add non-discrimination assurances
  • Add a private right of action.
  • Include strong civil rights protections

For the full letter, please see the attached PDF.