CIPP/US Study Guide
Chapter 6: State Comprehensive Privacy Laws

Cure Periods and the Private Right of Action

Cure periods split: California's expired; Colorado and Connecticut's sunset Dec 31, 2024; Utah and Virginia have a 30-day cure with no end date. No state has a traditional private right of action; California has only a limited one tied to data breaches.

Cure periods by state
StateCure period status
CaliforniaInitially had one; expired before this writing
ColoradoHas a cure period; sunsets Dec 31, 2024
ConnecticutHas a cure period; sunsets Dec 31, 2024
Utah30-day cure; no statutory end date
Virginia30-day cure; no statutory end date

None of the five laws has a traditional private right of action. Colorado, Connecticut, Utah, and Virginia provide none at all. California has only a limited private right of action (California) tied to security breaches of personal information (as defined in its breach-notification law) and to usernames/passwords - not to the general consumer rights in this chapter.

California's private action is breach-only

Don't overstate California's private right of action. It is limited to data breaches (and account credentials), not to the access/deletion/opt-out rights. The other four states give consumers no private right of action at all.

Key terms - quick answers

What is “Limited private right of action (California)”?
California's narrow right allowing individuals to sue over security breaches compromising personal information and over usernames/passwords, not over general consumer rights.