Vermont
Vermont Data Privacy and Online Surveillance Act (VDPOSA)
- Effective date
- January 1, 2028
- Enacted
- June 16, 2026
- Enforcement
- Vermont Attorney General
- Last reviewed
- October 3, 2026
Overview
At a Glance
Effective Date
January 1, 2028
Enforcement Authority
Vermont Attorney General
Consumer Request Deadline
45 days; one additional 45-day extension when reasonably necessary.
Cure Period
60-day cure opportunity applies January 1, 2028 through June 30, 2029 when the Attorney General determines cure is possible.
Universal Opt-Out / GPC
Yes
Private Right of Action
No
Sensitive Data Consent
Yes
Appeals Process
Yes
Applicability
Who Does This Law Apply To?
Applies based on personal-data, sensitive-data, or sale thresholds; consumer-health-data provisions have broader applicability.
Rights
Consumer Rights
Right to Opt Out of Sale
Opt out of sale of covered personal data as defined by the statute.
Right to Access
Confirm processing and access covered personal data, subject to statutory limits.
Right to Delete
Request deletion of covered personal data, subject to exceptions.
Right to Opt Out of Profiling
Opt out of qualifying profiling or solely automated decisions where provided.
Right to Correct
Request correction of inaccuracies in covered personal data.
Right to Data Portability
Obtain covered personal data in a portable format where the statute provides.
Right to Opt Out of Targeted Advertising
Opt out of covered targeted or cross-context behavioral advertising.
Obligations
Business Obligations
- AppealsRequiredInternal appeal process for denied rights requests.
- Data securityRequiredMaintain reasonable administrative, technical, and physical safeguards as required by the statute.
- Privacy noticeRequiredProvide required privacy disclosures/notices.
- Sensitive dataState-specificOpt-in consent is generally required before processing sensitive data, subject to statutory exceptions.
- Data minimizationRequired / state-specificLimit or govern collection/use consistent with the statute's duties and disclosed purposes.
- Universal opt outRequiredHonor qualifying opt-out preference signals/universal mechanisms.
- Processor contractsRequiredUse contracts governing processors/service providers as required.
- Consumer request processRequiredProvide methods for consumers to exercise statutory rights.
- Data protection assessmentRequiredConduct assessments for specified higher-risk processing.
Act 145 expressly requires a 45-day response, allows a 45-day extension, requires appeal responses within 60 days, and recognizes technology-based opt-out requests.
Exemptions
Common Exemptions
Exemptions are state-specific and may apply at the entity level, data level, or both. Verify the official statute before relying on an exemption. Treatment commonly varies for government, regulated financial/health information, higher education, nonprofits, employment data, and B2B data.
This list is not exhaustive.
Enforcement
Enforcement & Penalties
Authority: Vermont Attorney General
Enforced through Vermont consumer-protection authority; the Act does not create a general private right of action.
Sources
Sources & Verification
- View source
Vermont Data Privacy and Online Surveillance Act (statute)
State legislature
- View source
iapp.org
Secondary reference
- View source
ncsl.org
Secondary reference
- View source
privacylawnetwork.com
Secondary reference
- View source
ketch.com
Secondary reference
- View source
legislature.vermont.gov
Secondary reference
Last reviewed: October 3, 2026· Verified against official sources
From understanding to action
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Educational information only, not legal advice. Summaries may omit details; verify against the statute, regulations and official guidance.