Compliance Briefing — January 15, 2025
New Jersey’s Consumer Data Privacy Act begins enforcement, compelling controllers to honour opt-out rights, conduct data protection assessments, and secure heightened consent for children’s data.
Executive briefing: New Jersey Senate Bill 332 (A1971), the Consumer Data Privacy Act, becomes effective on January 15, 2025. Controllers handling personal data of 100,000 or more New Jersey consumers—or 25,000 consumers when earning revenue from selling personal data—must operationalise rights to access, correction, deletion, portability, and opt-out of targeted advertising. The statute requires privacy impact assessments for high-risk processing, mandates data minimisation, and compels consent before processing sensitive data, including precise geolocation and children’s information.
Key regulatory signals
- Universal opt-out signals. Controllers must process authenticated browser-based opt-outs within six months of the Attorney General specifying technical standards.
- Mandatory data protection assessments. High-risk processing such as targeted advertising, sale of personal data, profiling, or handling sensitive data requires documented assessments available to regulators.
- Children’s data guardrails. Selling or targeted advertising that uses personal data of consumers under 18 needs express opt-in consent.
Control alignment
- Inventory New Jersey consumers. Update data classification and residency tagging so systems can identify in-scope consumer records for DSR fulfilment.
- Automate privacy impact workflows. Embed DPIA triggers in product launch checklists and risk registers with Attorney General-ready documentation.
- Refresh consent journeys. Ensure just-in-time consent prompts and preference centres capture revocation timestamps for sensitive and under-18 users.
Detection and response priorities
- Log and reconcile opt-out signals across advertising platforms, data brokers, and internal activation systems.
- Monitor for profiling models that drive significant decisions about individuals and confirm DPIAs are complete before deployment.
Enablement moves
- Deliver training to growth, analytics, and data science teams on New Jersey-specific restrictions so campaigns avoid prohibited targeting without documented consent.
- Integrate appeal processes into customer care tooling so denied requests automatically trigger supervisory review windows.
Sources
- New Jersey S332/A1971: Consumer Data Privacy Act
- Office of the Governor: Governor Murphy signs comprehensive data privacy legislation
Zeph Tech unifies opt-out processing, DPIA orchestration, and residency-aware data mapping so New Jersey privacy compliance fuels trust instead of friction.