Covered companies will need to take additional steps to comply with the law in light of the new obligations relating to consumer health data and minors under 18 years old.

By Marissa R. Boynton, Serrin Turner, Joseph C. Hansen, Jennifer Howes, and Dyllan Brown-Bramble

On June 6, 2023, the Connecticut legislature passed Substitute Senate Bill No. 3 (SB3), which significantly amends the Connecticut Data Privacy Act (CTDPA), thereby broadening its reach. While the CTDPA took effect on July 1, 2023, the amendments do not yet apply.

The provisions in SB3 concerning consumer health data were originally drafted to take effect on July 1, 2023, alongside the rest of the CTDPA. However, a day after SB3 passed, the state budget bill amended the provisions related to consumer health data. The provisions will now take effect on October 1, 2023.

Separately, the requirements for dating app operators will take effect on January 1, 2024; the requirements for social media platforms will take effect on July 1, 2024; and the requirements for online providers of services, products, or features used by minors under 18 will take effect on October 1, 2024.