Governance Briefing — September 18, 2025
Vermont’s Data Privacy Act takes effect July 1, 2025, and boards need to ensure heightened-risk processing assessments, subcontractor controls, and consumer response governance are operating before the first post-go-live audits in late 2025.
Executive briefing: Vermont’s Data Privacy Act (H.121) became effective , introducing data protection assessments, sensitive data guardrails, and enforcement mechanisms for covered controllers. With the first quarter of operations underway, boards must evidence how heightened-risk processing is documented, how subcontractor governance functions, and how consumer rights workflows meet statutory timelines.
Board oversight checkpoints
- Data protection assessments. Confirm assessments are completed for targeted advertising, profiling that presents foreseeable harm, sale of personal data, and sensitive data processing per §2423, with board minutes showing review and challenge.
- Risk remediation tracking. Require management to document residual risks identified in assessments and the mitigation or acceptance decisions, including escalation criteria for high residual risk.
- Vendor governance. Ensure contracts with processors and subprocessors incorporate the statute’s required clauses on confidentiality, audit, and deletion, and that third-party inventories support regulator inquiries.
Operational priorities after go-live
- Request handling. Validate response playbooks for access, deletion, correction, and opt-out requests meet Vermont timelines and capture denials with rationale for appeals review.
- Sensitive data controls. Monitor consent logs, retention schedules, and access controls for biometric, precise geolocation, and children’s data classified as sensitive under the Act.
- Audit evidence. Establish evidence vaults containing assessments, training records, consumer request logs, and processor due-diligence packages to support Attorney General examinations.
Enablement moves
- Synchronise Vermont requirements with multistate privacy programmes to avoid conflicting opt-out interfaces and consent language.
- Integrate data privacy dashboards into quarterly board reporting showing request volumes, assessment status, and outstanding remediation actions.
- Deliver refresher training for business owners on identifying heightened-risk processing events, subcontractor onboarding expectations, and escalation paths.
Zeph Tech helps privacy officers operationalise Vermont’s Data Privacy Act with assessment tooling, evidence management, and board reporting routines.