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With the passage of the Colorado Privacy Act (CPA) during its latest legislative session, Colorado has become the third state to enact a comprehensive consumer data privacy law, following California and Virginia. Corporations that do business in Colorado will have two years to evaluate their data privacy practices and ensure they are prepared to comply with the CPA, which goes into effect on July 1, 2023.
Although the CPA does not feature groundbreaking privacy obligations, certain provisions do stand out. For instance, the law does not impose a revenue threshold, thus potentially subjecting small businesses who collect or profit from large amounts of personal data to comprehensive privacy obligations. Unlike the Virginia Consumer Data Protection Act (VCDPA), the CPA does not exempt nonprofits, nor does it expressly provide an entity-level exemption for organizations regulated by the Health Information Portability and Acc
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