U.S. Vermont Act 171 of 2018 — Data Broker Regulation

Why it Matters

Vermont Act 171 establishes regulatory oversight for data brokers,helping organizations build trust and accountability in personal datamanagement practices.

Key benefits include:

• Increase data handling transparency

Require cleardisclosures about data collection and sharing practices, ensuringindividuals and regulators better understand information handlingactivities.

• Strengthen consumer privacy protections

Mandate saferprocessing and storage of personal data, reducing the risk of misuseand unauthorized access.

• Enhance regulatory alignment

Helporganizations structure compliance programs to meet emerging stateand national privacy requirements more efficiently.

• Improve incident response readiness

Require promptnotification and remediation of security breaches, supporting moreeffective responses to data security incidents.

• Support responsible data stewardship

Encourageorganizations to adopt stronger governance practices and minimizereputational and regulatory risks related to personal data misuse.

How it Works

The U.S. Vermont Act 171 of 2018 — Data Broker Regulation organizesits framework around specific regulatory requirements targeting databroker practices, privacy safeguards, and transparency obligations.It establishes clear definitions for data brokers, outlinesregistration procedures, and stipulates disclosure mandatesconcerning data collection, usage, and security practices.

In practice, organizations that meet the definition of a data brokermust assess their status, register annually with the VermontSecretary of State, and implement governance measures to comply withthe act. Typical activities include developing explicit securitycontrols for personal data, conducting risk assessments to identifyand mitigate privacy risks, publishing comprehensive data practicesdisclosures, and maintaining ongoing compliance monitoring to meetstatutory obligations and support regulatory inspections.

With SmartSuite, organizations can operationalize Vermont Act 171compliance by leveraging modules for maintaining a control library ofstatutory requirements, documenting data handling practices, andtracking compliance through centralized registers. Capabilities forpolicy governance, evidence collection, and risk management supportcontinuous oversight, while reporting dashboards enable organizationsto demonstrate compliance readiness and transparency.

Key Elements

• Data Broker Registration Requirements

Specifiesmandatory registration procedures and disclosures for data brokersoperating within Vermont.

• Information Collection Practices

Outlines thetypes of personal information collected and the methods used by databrokers.

• Opt-Out and Consent Mechanisms

Describesprocesses allowing individuals to opt out of data collection or saleby data brokers.

• Security Standards and Safeguards

Establishesrequired measures data brokers must implement to protect collectedinformation from unauthorized access or use.

• Transparency and Disclosure Obligations

Requires brokersto provide clear public information regarding data handling policiesand business practices.

• Oversight and Enforcement Provisions

Definesregulatory authority, monitoring activities, and penalties fornon-compliance with the regulation.

Framework Scope

U.S. Vermont Act 171 of 2018 — Data Broker Regulation applies toentities engaged in the collection and sale of personal data aboutconsumers without direct relationships. The regulation governs databroker activities, including data processing systems and personalinformation management, and is typically adopted to meet statutorycompliance, enhance privacy protection, and support data governanceand regulatory assurance programs.

Framework Objectives

U.S. Vermont Act 171 of 2018 — Data Broker Regulation establishesrequirements to strengthen data protection and oversight for databrokers.

Enhance governance over the collection, processing, and sale ofpersonal data

Improve transparency and accountability in data broker operations andrisk management

Promote stronger regulatory compliance with consumer privacy andcybersecurity obligations

Support data protection by reducing unauthorized access and securitythreats

Ensure audit readiness through mandatory registration and requiredsecurity controls

Safeguard consumer interests by enabling clear disclosure of datapractices Vermont Act 171 aligns with U.S. privacy regulations likethe California Consumer Privacy Act (CCPA) and the Gramm-Leach-BlileyAct (GLBA), focusing specifically on data broker requirements.Organizations typically implement Vermont Act 171 to achieveregulatory compliance, particularly when handling personal data forprofiling, marketing, or resale within the state of Vermont.

Framework in Context

Vermont Act 171aligns with U.S. privacy regulations like the California ConsumerPrivacy Act (CCPA) and the Gramm-Leach-Bliley Act (GLBA), focusingspecifically on data broker requirements. Organizations typicallyimplement Vermont Act 171 to achieve regulatory compliance,particularly when handling personal data for profiling, marketing, orresale within the state of Vermont.

Common Framework Mappings

Vermont Act 171 is commonly mapped to established security andprivacy frameworks to ensure comprehensive data protection andregulatory alignment, especially for organizations managing sensitiveconsumer or brokered data across jurisdictions.

Mapped frameworks include:

CIS Critical Security Controls

CPRA (California Privacy Rights Act)

GDPR (General Data Protection Regulation)

ISO/IEC 27001

ISO/IEC 27701

NIST Cybersecurity Framework

NIST SP 800-53

PCI DSS

SOC 2

StateRAMP

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