Data Enforcement Rights Key U S Government Trends In 2025
Gretchen A. Ramos is global co-chair of Greenberg Traurig, LLP’s Data Privacy & Cybersecurity Practice. Jena M. Valdetero and David A. Zetoony are co-chairs of the firm’s U.S. Data Privacy & Cybersecurity Practice.
The practice is composed of a multidisciplinary group of attorneys and professionals located throughout the world. GT’s team of dedicated data protection attorneys have experience working hand in hand with organizations of all sizes to develop practical strategies and provide strategic advice on virtually all aspects of data protection including... GT’s Data Privacy & Cybersecurity Practice is ranked Band 1 by Chambers & Partners for USA – Nationwide Privacy & Data Security: Highly Regarded Legal Rankings. In addition, Greenberg Traurig was named a “Law Firm of the Year” for Information Technology Law by Best Law Firms® in 2024. As we enter the New Year, Wiley is looking ahead to the top privacy developments and trends to watch in 2025. On the state side, 2025 kicked off with several new privacy laws going into effect in January, and states continue ramping up enforcement activities.
At the federal level, privacy issues will likely remain a focus, particularly in the area of sensitive personal data, even if priorities shift in a new Administration. In addition to new laws and regulation, private litigation is expected to continue in certain key areas, and an expected upturn in transactions will make privacy-related due diligence critical. Below, we identify 10 privacy issues to watch this year. 1. New State Privacy Laws Are Effective and Are Being Enforced. The wave of state privacy laws is continuing this year.
In addition to eight laws that became effective in recent years, five new comprehensive state privacy laws take effect this month in Delaware, Iowa, Nebraska, New Hampshire, and New Jersey. Comprehensive privacy laws in Minnesota and Tennessee will take effect in July 2025, and Maryland’s Online Data Protection Act takes effect on October 1, 2025. All said, by the end of this year, the number of comprehensive state privacy laws in force will grow to 16. With the patchwork of comprehensive state privacy laws continuing to grow, many companies have moved towards a “nationwide approach,” adopting compliance plans that build on the commonalities and account for the outlier provisions among... However, there are differences that complicate compliance, including the scope of exceptions and treatment of sensitive data. The Maryland law in particular has stricter data minimization and sensitive personal data provisions than seen in other laws.
Subscribe to receive a monthly digest of articles exploring regulatory updates, news, trends and best practices in electronic communications capture and archiving. Smarsh handles information you submit to Smarsh in accordance with its Privacy Policy. By clicking "submit", you consent to Smarsh processing your information and storing it in accordance with the Privacy Policy and agree to receive communications from Smarsh and its third-party partners regarding products and services... You may withdraw your consent at any time by emailing [email protected]. TL;DR: State data privacy laws rapidly expanded in 2025, introducing new requirements for sensitive data, AI profiling, and universal opt-out signals. Businesses need adaptable, privacy-by-design compliance strategies to manage rising multi-state regulatory complexity.
US data privacy laws have entered a new era. Since 2018, landmark legislation, including the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), has transformed the way personal data is collected, used, and protected. Growing public concern over data misuse and pressure for stronger consumer protections have accelerated this shift, and the regulatory landscape is evolving faster than ever. What was once a patchwork of narrow, sector-specific rules has evolved into a complex and rapidly changing network of state privacy statutes, expanded consumer rights, and new compliance requirements. For organizations of every size, data privacy compliance is no longer optional or reactive. It is now central to corporate governance, brand reputation, and long-term success.
In part one of this series, we explored the most significant 2025 state privacy enforcement actions and what they reveal about regulators’ priorities. If you missed it, catch up on the trends, violations, and lessons every business needs to know. Part two goes beyond the headlines: we unpack how privacy enforcement is expanding, highlight emerging risks for organizations of all sizes, and provide concrete steps to strengthen your privacy program. From state AG investigations to class-action litigation, this blog delivers practical, actionable insights to help privacy teams anticipate regulatory pressure, mitigate risk, and build a privacy program that not only safeguards your business but... Enforcement Isn’t Just for Big Tech — It’s Everyone’s Challenge A common misconception is that privacy enforcement primarily targets large tech giants.
However, recent state enforcement actions reveal a far broader focus. Regulators are scrutinizing businesses across diverse industries from grocery stores and streaming services to car manufacturers and game developers. California’s enforcement sweeps, for example, have included companies operating loyalty programs and niche streaming platforms, many of which never anticipated being caught up in statewide privacy crackdowns. This demonstrates that if your business collects, processes, or shares personal data, regardless of size or industry, you are on the enforcement radar. Small and midsize businesses can no longer assume they are too small to be targeted. Privacy compliance is a universal requirement.
Written by: Jennifer A. Beckage, Esq., CIPP/US, CIPP/E and Lee Merreot, Esq., CIPM, CIPP/US, CIPP/E, CDPO For businesses operating in the United States, 2025 was a year of heightened scrutiny and evolving obligations. The U.S. remains unique: unlike the EU’s unified General Data Protection Regulation (GDPR) framework, it offers a patchwork of state and federal laws to address data security, privacy, and AI. This complexity—combined with rising litigation and regulatory actions—makes compliance a moving target for global organizations.
California continued to lead U.S. privacy enforcement, and two cases in particular illustrate why international companies should pay attention. American Honda Motor Co. became the first public enforcement action by the California Privacy Protection Agency (CPPA) under the CCPA. Honda was fined $632,500 for failing to honor opt-out preference signals and allegedly imposing excessive verification hurdles for consumer requests. The settlement required Honda to redesign its user experience and overhaul ad-tech contracts to meet statutory requirements.
[1] Similarly, Tractor Supply Co. agreed to pay $1.35 million after regulators found its privacy notices inadequate and opt-out mechanisms ineffective.[2] The landscape of American governance is undergoing a profound transformation in 2025. As digital technologies mature and citizen expectations evolve, federal, state, and local governments are fundamentally reimagining how they operate, regulate, and serve the public. This comprehensive analysis explores the most significant U.S.
government trends 2025, drawing on recent data, policy developments, and expert insights to map the changing contours of American governance. According to Granicus research, U.S. government agencies are now leveraging over 30 billion digital interactions annually to benchmark services, enhance citizen engagement, and streamline service delivery. This unprecedented data access is enabling a new era of evidence-based policymaking while simultaneously raising critical questions about privacy, equity, and algorithmic governance. As we navigate this complex transformation, three interconnected trends are emerging as particularly consequential: the datafication of governance, the privacy legislation surge, and the rise of state-led enforcement. 87% of federal agencies now have dedicated data analytics teams, up from 52% in 2020.
Data is no longer just an administrative tool—it has become the central nervous system of modern governance. Across all levels of government, agencies are harnessing big data, predictive analytics, and real-time monitoring to transform operations: Artificial intelligence has moved from experimental projects to core operational systems. The White House AI Implementation Index shows that 73% of federal agencies now have AI integrated into at least one mission-critical function. Common applications include: Enterprise CMP solutions to maximize opt-ins, ensure compliance, and unlock trusted data.
Centralized preference management to gain zero-party data and empower user control. Privacy-first digital analytics for compliant insights and measurable business impact. Server-side tracking to secure first-party data and enable compliant GA4 measurement. Consent Mode v2 to activate compliant, conversion-ready insights at scale.
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Gretchen A. Ramos Is Global Co-chair Of Greenberg Traurig, LLP’s
Gretchen A. Ramos is global co-chair of Greenberg Traurig, LLP’s Data Privacy & Cybersecurity Practice. Jena M. Valdetero and David A. Zetoony are co-chairs of the firm’s U.S. Data Privacy & Cybersecurity Practice.
The Practice Is Composed Of A Multidisciplinary Group Of Attorneys
The practice is composed of a multidisciplinary group of attorneys and professionals located throughout the world. GT’s team of dedicated data protection attorneys have experience working hand in hand with organizations of all sizes to develop practical strategies and provide strategic advice on virtually all aspects of data protection including... GT’s Data Privacy & Cybersecurity Practice is ran...
At The Federal Level, Privacy Issues Will Likely Remain A
At the federal level, privacy issues will likely remain a focus, particularly in the area of sensitive personal data, even if priorities shift in a new Administration. In addition to new laws and regulation, private litigation is expected to continue in certain key areas, and an expected upturn in transactions will make privacy-related due diligence critical. Below, we identify 10 privacy issues t...
In Addition To Eight Laws That Became Effective In Recent
In addition to eight laws that became effective in recent years, five new comprehensive state privacy laws take effect this month in Delaware, Iowa, Nebraska, New Hampshire, and New Jersey. Comprehensive privacy laws in Minnesota and Tennessee will take effect in July 2025, and Maryland’s Online Data Protection Act takes effect on October 1, 2025. All said, by the end of this year, the number of c...
Subscribe To Receive A Monthly Digest Of Articles Exploring Regulatory
Subscribe to receive a monthly digest of articles exploring regulatory updates, news, trends and best practices in electronic communications capture and archiving. Smarsh handles information you submit to Smarsh in accordance with its Privacy Policy. By clicking "submit", you consent to Smarsh processing your information and storing it in accordance with the Privacy Policy and agree to receive com...