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 data management practices.

Key benefits include:

• Increase data handling transparency

Require clear disclosures about data collection and sharing practices, ensuring individuals and regulators better understand information handling activities.

• Strengthen consumer privacy protections

Mandate safer processing and storage of personal data, reducing the risk of misuse and unauthorized access.

• Enhance regulatory alignment

Help organizations structure compliance programs to meet emerging state and national privacy requirements more efficiently.

• Improve incident response readiness

Require prompt notification and remediation of security breaches, supporting more effective responses to data security incidents.

• Support responsible data stewardship

Encourage organizations to adopt stronger governance practices and minimize reputational and regulatory risks related to personal data misuse.

How it Works

The U.S. Vermont Act 171 of 2018 — Data Broker Regulation organizes its framework around specific regulatory requirements targeting data broker practices, privacy safeguards, and transparency obligations. It establishes clear definitions for data brokers, outlines registration procedures, and stipulates disclosure mandates concerning data collection, usage, and security practices.

In practice, organizations that meet the definition of a data broker must assess their status, register annually with the Vermont Secretary of State, and implement governance measures to comply with the act. Typical activities include developing explicit security controls for personal data, conducting risk assessments to identify and mitigate privacy risks, publishing data practices disclosures, and maintaining ongoing compliance monitoring to meet statutory obligations and support regulatory inspections.

With SmartSuite, organizations can operationalize Vermont Act 171 compliance by using modules for maintaining a control library of statutory requirements, documenting data handling practices, and tracking compliance through centralized registers. Capabilities for policy governance, evidence collection, and risk management support continuous oversight, while reporting dashboards enable organizations to demonstrate compliance readiness and transparency.

Key Elements

• Data Broker Registration Requirements

Specifies mandatory registration procedures and disclosures for data brokers operating within Vermont.

• Information Collection Practices

Outlines the types of personal information collected and the methods used by data brokers.

• Opt-Out and Consent Mechanisms

Describes processes allowing individuals to opt out of data collection or sale by data brokers.

• Security Standards and Safeguards

Establishes required measures data brokers must implement to protect collected information from unauthorized access or use.

• Transparency and Disclosure Obligations

Requires brokers to provide clear public information regarding data handling policies and business practices.

• Oversight and Enforcement Provisions

Defines regulatory authority, monitoring activities, and penalties for non-compliance with the regulation.

Framework Scope

U.S. Vermont Act 171 of 2018 — Data Broker Regulation applies to entities engaged in the collection and sale of personal data about consumers without direct relationships. The regulation governs data broker activities, including data processing systems and personal information management, and is typically adopted to meet statutory compliance, enhance privacy protection, and support data governance and regulatory assurance programs.

Framework Objectives

U.S. Vermont Act 171 of 2018 — Data Broker Regulation establishes requirements to strengthen data protection and oversight for data brokers.

Enhance governance over the collection, processing, and sale of personal data

Improve transparency and accountability in data broker operations and risk management

Promote stronger regulatory compliance with consumer privacy and cybersecurity obligations

Support data protection by reducing unauthorized access and security threats

Ensure audit readiness through mandatory registration and required security controls

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

Framework in Context

Vermont Act 171 aligns with U.S. privacy regulations like the California Consumer Privacy Act (CCPA) and the Gramm-Leach-Bliley Act (GLBA), focusing specifically on data broker requirements. Organizations typically implement Vermont Act 171 to achieve regulatory compliance, particularly when handling personal data for profiling, marketing, or resale within the state of Vermont.

Common Framework Mappings

Vermont Act 171 is commonly mapped to established security and privacy frameworks to ensure data protection and regulatory alignment, especially for organizations managing sensitive consumer 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

‍