CIPP/US Study Guide
Chapter 7: State Data Breach Notification, Data Security, and Data Destruction Laws

State Data Security Laws

About two-thirds of states require data security measures. Roughly 20 states use a 'reasonable security' standard (e.g., California's AB 1950); about 10 impose prescriptive requirements (Massachusetts is the most prescriptive); and Connecticut, Iowa, Ohio, and Utah use safe harbor laws instead.

Less well known than breach laws, state data security laws require companies to develop and maintain appropriate data security. Federally, no law imposes security standards across all industries, but the health care and financial sectors have federal security provisions, and the FTC uses its Section 5 power to challenge misrepresented security (deceptive) or a failure to provide reasonable procedures (unfair).

Three approaches to state data security laws
ApproachRoughly how many statesExample
Reasonable security standard (no specifics)~20 statesCalifornia AB 1950
Prescriptive/extensive requirements~10 statesMassachusetts (most prescriptive: authentication, access controls, encryption, monitoring, firewalls, updates, training)
Cybersecurity safe harbor instead of obligations4 statesConnecticut, Iowa, Ohio, Utah
Sector-specific overlays

Some states impose sector-specific security mandates (e.g., financial services, insurance). New York has the most prominent of these.

Key terms - quick answers

What is “AB 1950”?
California's data security law (Civil Code 1798.81.5), the country's first state security law, requiring reasonable security procedures and practices.
What is “Cybersecurity safe harbor law”?
A law (Connecticut, Iowa, Ohio, Utah) letting a company defeat a breach lawsuit if it had appropriate safeguards in place before the breach.