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

Sensitive Personal Information

All five states treat citizenship, genetic/biometric data, physical/mental health, race/ethnicity, religion, and sexual orientation as sensitive. States add categories: Colorado, Connecticut, Virginia treat children's data as sensitive; California adds union membership, philosophical beliefs, and the content of communications.

All five states' definition of sensitive personal information includes citizenship; genetic and/or biometric information; physical or mental health conditions; race or ethnicity; religion; and sexual orientation.

Additional sensitive-data categories by state
Added categoryStates
Children's data treated as sensitiveColorado, Connecticut, Virginia
Geolocation as sensitiveCalifornia, Connecticut, Utah, Virginia
Union membership, philosophical beliefs, content of mail/email/textCalifornia (additional)
Children's data as sensitive - three states

Colorado, Connecticut, and Virginia treat children's data as sensitive personal information, which means processing it requires opt-in consent. This links directly to how those states handle children's data obligations.

Key terms - quick answers

What is “Sensitive personal information”?
A heightened category of personal data (e.g., health, race, religion, genetic/biometric data) that receives stronger protection under state comprehensive laws.