SIIA’s Concerns and Recommendations on Vermont H. 121: Balancing Privacy Protection and Business Compliance

The Software & Information Industry Association (SIIA) has expressed concerns regarding the current draft of Vermont H. 121. As a trade association representing diverse digital content providers and users, SIIA supports privacy protections for consumers and workable compliance requirements for businesses. While appreciating amendments to the definition of publicly-available information (PAI) to align with the First Amendment, SIIA suggests that additional clarity is needed in the section addressing “data brokers.” The definitions, data breach requirements, and opt-out and deletion language for data brokers are not aligned with general consumer privacy definitions, potentially causing compliance challenges. SIIA recommends cross-referencing opt-out and deletion requirements with general consumer privacy mandates to avoid confusion and maintain productive exemptions intended by the legislature. SIIA emphasizes the need to balance privacy protection with clear and feasible compliance for businesses, offering further discussion on these concerns.