The Iowa Consumer Data Protection Act (ICDPA) defines a “business” as any person that conducts business in Iowa or produces products or services targeted to Iowa consumers and that meets certain thresholds. These thresholds are based on the amount of revenue derived from selling personal data or engaging in targeted advertising, and the amount of personal data controlled or processed. Specifically, a business is subject to the ICDPA if, in the preceding calendar year, it controlled or processed the personal data of at least 100,000 Iowa consumers, or controlled or processed the personal data of at least 35,000 Iowa consumers and derived more than 50% of its gross revenue from selling personal data or deriving revenue from targeted advertising. The key here is understanding these quantitative thresholds. The scenario involves “AgriTech Solutions,” a company based in Illinois that sells agricultural software and services. AgriTech Solutions has collected personal data from 150,000 Iowa farmers. Of the total revenue of \( \$50,000,000 \), \( \$20,000,000 \) is derived from selling aggregated, anonymized data about crop yields and pest outbreaks, which is not considered “personal data” under the ICDPA. The remaining \( \$30,000,000 \) comes from software subscriptions and consulting services. AgriTech Solutions does not engage in targeted advertising based on consumer data. Since AgriTech Solutions controls or processes the personal data of 150,000 Iowa consumers, it meets the first threshold of 100,000 Iowa consumers, regardless of the revenue derived from selling anonymized data or the absence of targeted advertising. Therefore, AgriTech Solutions is considered a “business” under the ICDPA.

The Iowa Consumer Data Protection Act (ICDPA), effective January 1, 2025, grants consumers rights regarding their personal data. One such right is the right to opt-out of the sale of personal data. The ICDPA defines “sale” broadly to include the exchange of personal data for monetary consideration or other valuable consideration. However, the definition of sale excludes certain disclosures. Specifically, disclosures to a processor that processes the personal data on behalf of the controller, disclosures to a third party for the purpose of providing a product or service requested by the consumer, disclosures to a third party with whom the consumer has a direct relationship, and disclosures to a third party for the purpose of detecting and preventing fraud or protecting against security risks are generally not considered sales under the act. Furthermore, the act requires controllers to provide a clear and conspicuous link on their website titled “Do Not Sell My Personal Information” or a similar phrase. This link must lead to a page where consumers can exercise their opt-out rights. The ICDPA does not require a specific monetary threshold for a transaction to be considered a sale. The primary consideration is whether valuable consideration is exchanged for the personal data. The act also emphasizes the importance of consent for certain data processing activities, particularly sensitive data, and requires clear privacy notices. The scope of personal data covered by the ICDPA is broad, encompassing information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The act’s enforcement mechanism involves the Iowa Attorney General.

The Iowa Consumer Data Protection Act (ICDPA), effective January 1, 2025, establishes specific rights for Iowa consumers regarding their personal data and obligations for controllers. One key aspect is the definition of “personal data” and “sensitive data.” Personal data is broadly defined as any information that is linked or reasonably linkable to an identified or identifiable natural person. Sensitive data, a subset of personal data, includes a more restricted category of information that, if disclosed, could result in substantial risk of harm to the consumer. This category encompasses data revealing racial or ethnic origin, religious or philosophical beliefs, a trade union membership, the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, sex life, or sexual orientation, and in certain circumstances, precise geolocation data. Under the ICDPA, a consumer has the right to obtain a list of all specific third parties to whom their personal data has been disclosed. This right is designed to enhance transparency and allow consumers to understand the extent of data sharing by businesses. While the law grants consumers rights concerning access, correction, deletion, and opting out of the sale of personal data, the right to a comprehensive list of specific third-party disclosures is a distinct and important consumer protection measure. This provision is critical for consumers to exercise control over their digital footprint and understand the potential privacy implications of data sharing practices. The ICDPA’s framework is designed to align with other state privacy laws, but its specific implementation details, including the scope of this disclosure right, are unique to Iowa’s legislative approach.

The scenario presented involves a data breach affecting personal information of Iowa residents. The core issue is determining the notification obligations under Iowa law. Iowa Code Chapter 715C outlines the requirements for data breach notification. Specifically, it mandates that a person who conducts business in Iowa and owns or licenses computerized data which includes personal information shall notify each affected Iowa resident of the breach. The notification must be made in the most expedient time possible and without unreasonable delay, consistent with the legitimate needs of law enforcement or the measures necessary to determine the scope of the breach and restore the integrity of the data system. The law defines “personal information” broadly to include a consumer’s first name or first initial and last name in combination with any one or more of the following data elements, when the data element is not encrypted, or is encrypted but the encryption key or other solution to the encryption is also accessed or acquired: social security number, driver’s license number, state identification card number, account number, credit or debit card number, or any required security code, access code, or password that would permit access to a consumer’s financial account. In this case, the compromised data includes names, email addresses, and encrypted social security numbers where the encryption key was also accessed. This constitutes “personal information” as defined by Iowa Code Section 715C.1. Therefore, the entity is obligated to notify affected Iowa residents. The notification must be provided without unreasonable delay, and given that the breach was discovered on October 15th and the investigation concluded on November 5th, providing notification by November 15th is within a reasonable timeframe, particularly considering the need to confirm the scope and nature of the compromise. The law does not specify a fixed number of days but emphasizes expediency and lack of unreasonable delay. The notification content must include a description of the incident, the types of personal information involved, the steps the person has taken to address the incident, and advice the consumer may take to protect themselves. The question asks about the legal obligation to notify, which is clearly established.

The Iowa Consumer Data Protection Act (ICDPA) grants consumers the right to opt-out of the sale of personal data and targeted advertising. A controller must provide a clear and conspicuous link on their website titled “Do Not Sell or Share My Personal Information” or “Do Not Sell My Personal Information” for consumers to exercise this right. This link should lead to a process allowing consumers to submit a request. If a controller has a good-faith belief that a request is inauthentic, they may deny it. However, the ICDPA does not mandate a specific timeframe for verifying the authenticity of a request beyond what is reasonable under the circumstances, nor does it require controllers to respond to every opt-out request regardless of perceived authenticity. The primary obligation is to provide a mechanism for opt-out and to honor valid requests. The concept of a “reasonable period” for verification is key, but the law does not prescribe a fixed number of days for this. Therefore, a controller is not obligated to respond within a specific, short number of days to every request if they have a good-faith belief it is inauthentic, but they must have a process in place and honor valid requests.

The Iowa Consumer Data Protection Act (ICDPA), effective January 1, 2025, grants Iowa consumers specific rights regarding their personal data. One crucial aspect is the right to opt-out of the sale of personal data and targeted advertising. When a controller receives a request to opt-out, they must respond within a specified timeframe. The ICDPA mandates that controllers must act on an opt-out request without undue delay, and in any case, not later than 45 days after receiving the request. This period can be extended by an additional 45 days if reasonably necessary, provided the controller informs the consumer of the extension and the reason for the delay within the initial 45-day period. This timeframe is critical for ensuring consumer privacy rights are respected promptly. The law also specifies requirements for how opt-out requests should be handled, including the use of universal opt-out mechanisms. Understanding these deadlines is paramount for compliance.

The scenario involves a business operating in Iowa that collects and processes personal information of Iowa residents. The question probes the specific obligations under Iowa’s data privacy law, the Iowa Consumer Data Protection Act (ICDPA). The ICDPA, like many state privacy laws, imposes requirements on controllers and processors of personal data. A key aspect of these laws is the obligation to conduct and document Data Protection Assessments (DPAs) for certain processing activities deemed to pose a heightened risk of harm to consumers. Such activities typically include targeted advertising, selling personal data, and processing sensitive data. In this case, the business is engaging in targeted advertising and selling personal data, which are explicitly listed as activities requiring a DPA. Therefore, the business must conduct and document a DPA for these specific processing activities to comply with Iowa law. The ICDPA does not mandate a DPA for all data processing, nor does it require one solely based on the volume of data collected or the business’s location within Iowa, though the latter is a prerequisite for the law’s applicability. The requirement is tied to the *nature* of the processing activity and its potential risk to consumers.

The Iowa Consumer Data Protection Act (ICDPA) outlines specific requirements for businesses that process personal data of Iowa residents. One key aspect is the definition of “selling” personal information. Under the ICDPA, selling personal information is defined as exchanging personal information for monetary or other valuable consideration. This broad definition encompasses situations where a business shares data with a third party for targeted advertising purposes, even if no direct payment is exchanged, if the sharing is part of a broader commercial transaction that provides value to the business. The act also distinguishes between selling data and sharing data for other purposes, such as fulfilling a consumer request or for operational purposes with a service provider who is contractually obligated to protect the data. Therefore, when a business shares consumer data with an analytics firm for the purpose of developing personalized marketing strategies that ultimately aim to increase sales or brand engagement, and this sharing is compensated or provides a reciprocal benefit beyond mere service provision, it constitutes a sale under the ICDPA. The presence of “other valuable consideration” is crucial here, meaning it doesn’t have to be purely monetary. The ICDPA’s approach is consistent with other state privacy laws in its expansive view of what constitutes a “sale” to protect consumer privacy in the digital economy.

The Iowa Consumer Data Protection Act (ICDPA) grants consumers the right to opt out of the sale of personal data and the processing of personal data for targeted advertising or profiling. When a controller receives a request to opt out of the sale of personal data, the controller must comply with the request within 45 days of receiving it. This period can be extended by an additional 45 days if the controller informs the consumer of the extension and the reasons for the delay. The ICDPA does not mandate a specific calculation for determining the exact day of compliance; rather, it specifies the maximum timeframe. For a request received on April 1st, the initial 45-day period would conclude on May 16th. If an extension is warranted and communicated, the compliance deadline could be extended to June 30th. The core principle is adherence to the statutory timelines and proper notification to the consumer regarding any extensions. The law emphasizes timely action and transparency in handling consumer rights requests.

The scenario involves a data breach affecting residents of Iowa. Iowa’s data privacy law, the Iowa Consumer Data Protection Act (ICDPA), mandates specific actions following a breach of personal data. The law requires notification to affected individuals without unreasonable delay, and in any event, no later than 45 days after the discovery of the breach. It also necessitates notification to the Iowa Attorney General if the breach affects 500 or more Iowa residents. The definition of “personal data” under ICDPA includes information that can be used to identify an individual, such as names, addresses, or social security numbers. The scenario specifies that a breach occurred, exposing the names and email addresses of 750 Iowa residents. This quantity exceeds the 500-resident threshold for notifying the Attorney General. Therefore, the company is obligated to notify both the affected individuals and the Iowa Attorney General. The timeline for individual notification is critical, emphasizing “without unreasonable delay” and a maximum of 45 days. The Attorney General notification must also be timely, typically aligning with the individual notification period.

The Iowa Consumer Data Protection Act (ICDPA) grants consumers rights regarding their personal data held by businesses. One of these rights is the right to opt-out of the sale of personal data. The ICDPA defines “sale” broadly to include the exchange of personal data for monetary or other valuable consideration. When a consumer exercises their right to opt-out of the sale of their personal data, a controller must honor this request. This obligation extends to third parties with whom the controller has already shared the data, requiring the controller to provide notice to those third parties about the opt-out. The ICDPA does not mandate that the controller must cease all processing of the consumer’s data, but rather specifically targets the sale. The act also provides a mechanism for consumers to appeal a controller’s refusal to act on their request. Therefore, when a controller receives a valid opt-out request from an Iowa resident regarding the sale of their data, their primary obligation is to cease selling that data and to notify any third parties who have received the data for sale purposes. The requirement to provide a dedicated opt-out mechanism is a proactive measure mandated by the law.

The scenario involves a company based in Iowa that processes personal data of individuals residing in Iowa. The question probes the applicability of Iowa’s consumer data privacy law, the Iowa Consumer Data Protection Act (ICDPA), to a specific business operation. The ICDPA, like many state-level privacy laws, has thresholds for applicability based on the volume of data processed and the revenue generated from selling consumer data. Specifically, for the law to apply to a controller, it must conduct business in Iowa or produce goods or services targeted to consumers in Iowa and, during the preceding calendar year, control or process the personal data of at least 100,000 consumers, or control or process the personal data of at least 35,000 consumers and derive more than 50% of its gross revenue from selling consumer data or controlling/processing volatile data. In this case, the company processes data for 90,000 consumers and does not sell data. Therefore, it does not meet either of the primary thresholds for applicability under the ICDPA. The law’s provisions, such as granting consumers rights to access, delete, and opt-out of the sale of their personal data, would not be mandated for this company’s operations concerning Iowa residents under these specific circumstances.

The scenario describes a data breach affecting a company operating in Iowa. The company’s data processing activities involve the collection of sensitive personal information, including health-related data, from Iowa residents. The breach resulted in the unauthorized acquisition of this data. Iowa’s data breach notification law, Iowa Code Chapter 715C, mandates that a person who conducts business in Iowa and owns or licenses computerized data that includes personal information shall notify each affected resident of the breach of the security of the system. The definition of “personal information” under Iowa law includes first name or first initial and last name in combination with any one or more of the following data elements, when such data is not encrypted, or is encrypted with an encryption key that has been accessed or obtained: social security number, driver’s license number, Iowa identification card number, account number, credit or debit card number, or any security code or password that would permit access to a financial account. Importantly, for the purposes of this notification requirement, “personal information” also includes a resident’s “health information” or “medical information” if it is not protected by federal law such as HIPAA, or if it is combined with any of the aforementioned identifiers. In this specific case, the data compromised includes “sensitive personal information” and “health-related data” of Iowa residents. While HIPAA may apply to some health data, the question implies that the compromised data, or at least a portion of it, falls outside of strict HIPAA protection or is combined with identifiers that trigger Iowa’s law. Therefore, the company is obligated to provide notification to affected Iowa residents under Iowa Code Chapter 715C. The timing of notification is also crucial; it must be made without unreasonable delay and no later than 60 days after discovery of the breach, unless a longer period is required by specific circumstances or if law enforcement determines that notification would impede an investigation. The notification must include specific details about the breach and steps individuals can take to protect themselves.

The scenario describes a data breach affecting a business operating in Iowa. The notification requirements under Iowa’s data privacy law, specifically the Iowa Act Relating to Data Protection (often referred to as the Iowa Consumer Data Protection Act or ICDPA), are triggered when there is an unauthorized acquisition of computerized data that compromises the security, confidentiality, or integrity of personal information. The law requires notification to affected Iowa residents without unreasonable delay, and in any event, no later than 45 days after discovery of the breach. The notification must be provided by written communication, electronic communication, or, if the person agrees to it, by telephone communication. The law also specifies the content of the notification, which must include a description of the incident, the type of information involved, steps individuals can take to protect themselves, and contact information for the entity. The key here is understanding the trigger for notification and the timeframe. The fact that the breach involved a “significant number” of Iowa residents and included sensitive personal information like Social Security numbers and financial account details clearly meets the threshold for mandatory notification under Iowa law. The prompt asks about the specific requirement regarding the *method* of notification when no agreement for telephone notification is made. Iowa law mandates written or electronic communication in such cases.

The Iowa Consumer Data Protection Act (ICDPA) defines a “business” as any person that conducts business in Iowa or produces products or services for residents of Iowa and meets certain thresholds. These thresholds relate to the amount of personal data processed or controlled. Specifically, a business is subject to the ICDPA if, in the preceding calendar year, it controlled or processed the personal data of at least 100,000 Iowa consumers, excluding personal data processed solely for the purpose of completing an electronic fund transfer. Alternatively, a business is subject if it controlled or processed the personal data of at least 35,000 Iowa consumers and derived more than 35% of its gross revenue from selling personal data. The key here is that the thresholds are applied to the number of Iowa consumers whose data is processed or sold, not the total number of transactions or the overall revenue. Therefore, a business that processes the personal data of 90,000 Iowa consumers, even if it derives 50% of its gross revenue from selling personal data, would not meet the second threshold, as the number of consumers is below 35,000. Similarly, if a business processes data for 120,000 consumers but the data is solely for completing electronic fund transfers, it would be exempt. The question focuses on the revenue threshold combined with the number of consumers. For the second prong of the definition, the business must process the personal data of at least 35,000 Iowa consumers AND derive more than 35% of its gross revenue from selling personal data. Processing data for 90,000 consumers does not meet the 35,000 consumer threshold for the second prong.

The scenario describes a situation where a company operating in Iowa collects sensitive personal data from its customers. The company then engages a third-party vendor located in another state to process this data. The critical element here is the transfer of personal data across state lines for processing, which implicates data protection obligations under Iowa law, particularly the Iowa Consumer Data Protection Act (ICDPA). The ICDPA, like many state privacy laws, imposes duties on controllers regarding the processing of consumer data and requires due diligence when engaging processors. A key requirement for controllers is to establish a written contract with processors that clearly outlines the processor’s obligations concerning data protection. This contract must specify the nature, purpose, and duration of the processing, the types of personal data involved, and the rights and obligations of both parties. Furthermore, the contract should mandate that the processor implement reasonable security measures to protect the data and assist the controller in fulfilling data subject rights requests. Without such a contract, the controller is failing to meet its statutory obligations to ensure the secure and lawful processing of consumer data by third parties. The ICDPA’s framework emphasizes a shared responsibility model where controllers remain accountable for data processed by their vendors. Therefore, the absence of a written contract with the vendor processing sensitive personal data represents a direct violation of the controller’s duty to oversee and ensure the protection of consumer data under Iowa’s privacy framework.

The Iowa Consumer Data Protection Act (ICDPA) establishes specific requirements for businesses that collect and process personal data of Iowa residents. One key aspect is the definition of a “covered entity” and the thresholds that trigger compliance. A business becomes a covered entity under the ICDPA if, during the preceding calendar year, it controlled or processed the personal data of at least 100,000 Iowa consumers, OR it controlled or processed the personal data of at least 35,000 Iowa consumers and derived more than 50% of its gross revenue from selling personal data or controlling/processing personal data. The question presents a scenario where a company’s revenue is derived from various sources, and we need to determine if it meets the threshold based on the ICDPA’s provisions. Let’s analyze the company’s data processing activities for the preceding calendar year: Total Iowa consumers whose personal data was processed: 75,000 Total Iowa consumers whose personal data was sold: 25,000 The ICDPA has two alternative thresholds for a business to be considered a “covered entity”: Threshold 1: Control or process the personal data of at least 100,000 Iowa consumers. Threshold 2: Control or process the personal data of at least 35,000 Iowa consumers AND derive more than 50% of its gross revenue from selling personal data or controlling/processing personal data. In this scenario, the company processed the personal data of 75,000 Iowa consumers. This number (75,000) is less than the first threshold of 100,000 consumers. Now let’s evaluate the second threshold. The company processed the personal data of 75,000 Iowa consumers, which meets the “at least 35,000 Iowa consumers” part of the second threshold. However, the second part of this threshold requires that “more than 50% of its gross revenue” be derived from selling personal data or controlling/processing personal data. The problem states that 60% of its gross revenue comes from selling software licenses and 40% comes from providing cloud services. It does not explicitly state that the revenue from selling personal data or controlling/processing personal data exceeds 50% of its gross revenue. In fact, the provided revenue breakdown indicates that the primary revenue sources are software licenses and cloud services, not the sale or processing of personal data in a way that would constitute the majority of its revenue. Therefore, the company does not meet the second threshold either. Since the company does not meet either of the two alternative thresholds for being a “covered entity” under the Iowa Consumer Data Protection Act, it is not subject to the Act’s requirements. The ICDPA’s applicability is contingent upon meeting these specific quantitative thresholds. The Act’s definitions and scope are carefully delineated to apply to businesses of a certain size and operational model concerning consumer data. The provided revenue streams do not align with the criteria for exceeding the revenue threshold related to data sales or processing.

The Iowa Consumer Data Protection Act (ICDPA), effective January 1, 2025, grants consumers rights concerning their personal data collected by controllers. One significant right is the right to opt-out of the sale of personal data, as well as the processing of personal data for targeted advertising or profiling. The definition of “sale” under the ICDPA is broad, encompassing the exchange of personal data for monetary consideration, but importantly, it also includes the exchange of personal data for other valuable consideration. This includes situations where a controller shares data with a third party for advertising purposes, even if no direct payment is exchanged, if the third party uses the data to benefit the controller in some way, such as by providing insights or improving services. The key is the transfer of data for a benefit, whether monetary or otherwise. Therefore, if a company in Iowa shares customer email lists with an advertising partner in exchange for analytics that help refine the company’s marketing strategies, this constitutes a “sale” under the ICDPA because valuable consideration (the analytics) is exchanged for personal data. The controller must provide a clear and conspicuous link titled “Do Not Sell or Share My Personal Information” or a similar designation, allowing consumers to exercise this right.

The scenario involves a data breach affecting a company operating in Iowa. The core of the question revolves around the notification requirements under Iowa’s data breach law. Iowa Code Chapter 715C, the state’s data security breach notification law, mandates that any entity that conducts business in Iowa and owns or licenses computerized data that includes personal information of a resident of Iowa, and experiences a breach of the security of the system containing that data, must notify affected residents without unreasonable delay. The law defines “personal information” broadly, including a resident’s first name or first initial and last name in combination with any one or more of the following data elements: social security number, driver’s license number, state identification card number, or account number, credit or debit card number, in any form that allows access to the individual’s financial account. The law also specifies exceptions, such as when the information is encrypted or otherwise rendered unreadable and un-usable. In this case, the breach involves unencrypted medical records and social security numbers, which clearly constitute personal information under the statute. The delay in notification, from discovery to notification, is stated as 60 days. Iowa law requires notification “without unreasonable delay.” While “unreasonable delay” is not precisely quantified, 60 days for a confirmed breach of sensitive data like unencrypted medical records and social security numbers would generally be considered unreasonable, especially when compared to the typical 30-day timeframe seen in many other state laws, although Iowa’s statute does not specify a hard deadline. The notification must include specific content, such as a description of the incident, the types of personal information involved, steps individuals can take to protect themselves, and contact information for the entity. The question asks about the legal implication of the delay. The delay itself, if deemed unreasonable, could lead to regulatory scrutiny and potential penalties, but the primary legal obligation triggered by the breach is the notification itself. The question probes the understanding of what constitutes a trigger for notification and the general expectation of timeliness. The absence of a specific mention of a “good faith” effort to mitigate harm or a specific safe harbor provision in the prompt means the focus remains on the direct notification obligation. The key is that the data was unencrypted and contained sensitive personal information, and a breach occurred. The subsequent delay, while potentially problematic, does not negate the initial obligation to notify. The question tests the understanding that the breach of unencrypted sensitive data itself triggers the notification requirement, irrespective of the subsequent delay’s specific legal consequence in terms of penalty quantification, which is not the focus of the question. The correct answer reflects the fundamental trigger for notification.

The scenario involves a data breach affecting Iowa residents’ personal information. The core issue is determining the notification obligations under Iowa law. Iowa Code Chapter 715C outlines the requirements for data breach notification. Specifically, it mandates that a business that owns or licenses computerized data that includes personal information shall disclose any breach of the security of the system following discovery or notification of the breach. The notification must be made without unreasonable delay, and in any event, no later than 60 days after discovery of the breach, unless a longer period is required for specific reasons such as law enforcement investigations. The notification must be provided to any resident of Iowa whose personal information was, or is reasonably believed to have been, acquired by an unauthorized person. The content of the notification must include a description of the incident, the types of personal information involved, the steps the business has taken to address the incident, and advice that the resident can take to protect themselves. In this case, the breach occurred on March 1st, and the notification was sent on April 15th. This timeframe of 45 days is well within the 60-day statutory limit. The information compromised includes names, addresses, and social security numbers, which clearly fall under the definition of personal information requiring notification. The fact that the company is based in California and the breach affected residents of multiple states does not exempt them from Iowa’s specific notification requirements for its Iowa-domiciled residents. The law focuses on the residency of the affected individuals, not the location of the business. Therefore, the notification provided on April 15th to the affected Iowa residents fulfills the statutory obligation under Iowa Code Chapter 715C.

The core of this question revolves around understanding the specific notification requirements under Iowa’s data breach law, specifically Iowa Code Chapter 715C. This chapter mandates that a breach of security involving computerized personal information must be reported to affected individuals and, in certain circumstances, to the Iowa Attorney General. The law defines “personal information” broadly to include information that can be used to identify an individual, and “breach of security” as unauthorized acquisition of unencrypted computerized personal information that creates a risk of identity theft or fraud. When a breach affects residents of Iowa, the notification must be made without unreasonable delay and in the most expedient time possible, generally no later than 45 days after discovery of the breach, unless a longer period is required for investigation by law enforcement. The notification must include specific details about the breach, such as the nature of the information compromised and steps individuals can take to protect themselves. A critical aspect is the threshold for notification: if the breach involves more than 500 Iowa residents, the data controller must also notify the Iowa Attorney General. In this scenario, the breach affects 750 Iowa residents, exceeding the 500-resident threshold, thus triggering the requirement to notify the Iowa Attorney General in addition to the affected individuals.

The Iowa Consumer Data Protection Act (ICDPA), effective January 1, 2025, outlines specific obligations for businesses regarding the processing of personal data of Iowa residents. A key aspect of this legislation, mirroring trends in other states like California, is the requirement for controllers to conduct and document Data Protection Assessments (DPAs) for processing activities that present a heightened risk of harm to consumers. These heightened risk activities include targeted advertising, the sale of personal data, and certain profiling activities. The ICDPA does not mandate DPAs for all data processing, but rather for those identified as posing a significant risk. The purpose of a DPA is to identify and mitigate risks associated with the processing of personal data. The law specifies that these assessments should be conducted annually for processing activities that present a heightened risk. The question asks about the specific frequency of these assessments for such high-risk activities. Therefore, an annual review is the mandated frequency for processing activities identified as posing a heightened risk of harm.

The scenario involves a data breach affecting residents of Iowa. The Iowa Consumer Data Protection Act (ICDPA), effective January 1, 2023, governs the processing of personal data of Iowa residents. While the ICDPA does not mandate a specific notification period in days for data breaches, it requires controllers to notify affected consumers without unreasonable delay and in accordance with any requirements of federal law. Federal law, such as the Health Insurance Portability and Accountability Act (HIPAA) for protected health information, or state-specific breach notification laws, might impose stricter timelines. However, in the absence of a specific statutory timeframe within the ICDPA itself for general consumer data breaches, the principle of “without unreasonable delay” is the governing standard. This implies a prompt notification, typically within a few weeks, depending on the complexity of the breach investigation and the need to identify affected individuals. The notification must also be provided to the Iowa Attorney General if the breach affects at least 500 Iowa residents. The key here is the absence of a fixed number of days in the ICDPA for general consumer data breaches, unlike some other states that specify 30, 45, or 60 days. Therefore, the most accurate description of the notification requirement under Iowa law for a general consumer data breach, in the absence of specific federal mandates overriding this aspect of the ICDPA, is notification without unreasonable delay.

The Iowa Consumer Data Protection Act (ICDPA), effective January 1, 2025, grants consumers rights regarding their personal data collected by controllers. A key aspect is the right to opt-out of the sale of personal data, targeted advertising, and profiling for decisions producing legal or similarly significant effects. When a controller receives a valid request to opt-out of these activities, the controller must honor the request without undue delay, and in any event, within 45 days of receiving the request. This period can be extended by an additional 45 days if reasonably necessary, provided the controller informs the consumer of such an extension within the initial 45-day period, along with the reasons for the delay. The ICDPA does not mandate specific mathematical calculations for opt-out processing timelines but establishes a clear temporal framework for compliance. The scenario describes a controller receiving an opt-out request on March 1st. The initial 45-day period would conclude on April 15th. If an extension is necessary, the controller must notify the consumer by April 15th. The extended period would then end 45 days after April 15th, which is May 30th. Therefore, the absolute latest date for a controller to cease processing personal data for targeted advertising, following a valid opt-out request received on March 1st and a justified extension, is May 30th. This timeline reflects the statutory obligations under Iowa law for responding to consumer data rights requests, emphasizing timely action and transparent communication.

The Iowa Consumer Data Protection Act (ICDPA), effective January 1, 2025, aligns with many other state privacy laws by establishing specific rights for consumers regarding their personal data and obligations for controllers. One key aspect of these laws is the definition of “personal data” and the scope of entities to which they apply. The ICDPA defines personal data broadly as information that is linked or reasonably linkable to an identified or identifiable natural person. It does not apply to certain types of data, such as deidentified data or publicly available information. Furthermore, the law outlines thresholds for applicability based on the volume of personal data processed or revenue generated. Specifically, a controller is subject to the ICDPA if, in the preceding calendar year, they controlled or processed the personal data of at least 100,000 Iowa consumers, excluding personal data processed solely for the purpose of completing a consumer-initiated transaction, OR if they derived 50% or more of their annual gross revenue from selling personal data, controlling or processing the personal data of at least 35,000 Iowa consumers. This latter threshold is designed to capture businesses whose primary revenue stream is data sales, even if their overall consumer base is smaller. The distinction between processing for a consumer-initiated transaction and other processing is crucial for determining whether the 100,000 consumer threshold is met.

The scenario presented involves a data breach affecting a business operating primarily within Iowa, impacting the personal information of Iowa residents. Iowa’s data breach notification law, specifically codified in Iowa Code Chapter 715C, mandates specific actions when a breach of security occurs. The law defines a “data breach” as an unauthorized acquisition of or access to unencrypted or unredacted computerized data that includes personal information. It requires notification to affected individuals and, in certain circumstances, to the Iowa Attorney General’s office. The timing of notification is crucial; it must be made without unreasonable delay and no later than 60 days after discovery of the breach, unless a longer period is required for investigation by law enforcement. The law also specifies the content of the notification, which generally includes a description of the incident, the types of personal information involved, and steps individuals can take to protect themselves. When a breach affects more than 500 Iowa residents, notification to the Attorney General is also required. The key here is that the business itself discovered the breach and is obligated to take action. The scenario does not mention any third-party vendor involvement that might shift the primary notification responsibility, nor does it indicate a delay for law enforcement investigation that would extend the notification period beyond the statutory maximum without justification. Therefore, the business must initiate the notification process directly to the affected Iowa residents and the Iowa Attorney General, adhering to the statutory timelines and content requirements.

The Iowa Consumer Data Protection Act (ICDPA) defines a “covered entity” as a person that conducts business in Iowa or produces products or services targeted to consumers in Iowa and meets certain thresholds related to processing personal data. Specifically, a covered entity is one that, during the preceding calendar year, controlled or processed the personal data of at least 100,000 Iowa consumers, or controlled or processed the personal data of at least 35,000 Iowa consumers and derived more than 50 percent of its gross revenue from selling personal data or deriving revenue from targeted advertising. The threshold of 100,000 consumers is a key figure for determining applicability, as is the alternative threshold involving a combination of consumer data processing and revenue from specific activities. The ICDPA’s scope is thus tied to the volume of data processed and the business model involving data sales or targeted advertising, reflecting a tiered approach to consumer data protection based on the scale and nature of a business’s data handling practices within Iowa. Understanding these specific numerical thresholds is crucial for businesses to determine their obligations under Iowa law.

The Iowa Consumer Data Protection Act (ICDPA) defines a “covered entity” as a person that conducts business in Iowa or produces goods or services that are directed to consumers who are Iowa residents and that alone or in the aggregate satisfies one of the following thresholds: controls or processes the personal data of at least 100,000 consumers, or controls or processes the personal data of at least 35,000 consumers and derives more than 50 percent of its gross revenue from selling personal data. This definition is crucial for determining which businesses are subject to the law’s requirements regarding consumer rights and data protection. The thresholds are not based on a calculation involving revenue percentage and data volume simultaneously in a multiplicative or additive manner, but rather on satisfying *either* the volume of consumers controlled or processed *or* a combination of a lower volume of consumers and a significant revenue derivation from selling personal data. Therefore, a business meeting either the 100,000 consumer threshold *or* the 35,000 consumer threshold combined with more than 50% of gross revenue from selling personal data would be considered a covered entity. The question tests the understanding of these distinct alternative thresholds.

The scenario involves a data breach affecting a business operating in Iowa that processes personal information of Iowa residents. Iowa’s data privacy law, the Iowa Consumer Data Protection Act (ICDPA), mandates specific actions in the event of a data breach. The law requires a business to conduct an investigation to determine the nature and scope of the breach, and to notify affected individuals and the Iowa Attorney General without unreasonable delay. The ICDPA defines a data breach as an unauthorized acquisition of computerized personal data that compromises the security, confidentiality, or integrity of the personal data. The notification to the Attorney General must include specific information about the breach, the number of affected individuals, and the steps the business is taking. The law also specifies a timeframe for notification, which is “without unreasonable delay,” generally interpreted as within 60 days if the Attorney General’s office requests it, or as soon as practicable. In this case, the business identified the breach on October 15th and initiated an investigation. The investigation confirmed that 5,000 Iowa residents’ personal data was accessed. The business then promptly notified the Iowa Attorney General and all affected individuals on November 1st. This timeline of approximately 17 days from discovery to notification aligns with the “without unreasonable delay” standard and the requirements of the ICDPA for reporting data breaches to the Attorney General and affected consumers. The promptness of the notification, coupled with the confirmation of the breach’s impact on Iowa residents, fulfills the core obligations under Iowa’s data protection statute.

Iowa’s approach to data breach notification is primarily governed by Iowa Code Chapter 715C, which outlines the requirements for businesses to notify affected individuals in the event of a data breach involving personal information. The statute defines what constitutes personal information and specifies the content of the notification, including the nature of the breach, the types of information compromised, and steps individuals can take to protect themselves. It also details the timeframe for notification, generally without unreasonable delay and no later than 60 days after discovery, unless a longer period is required for specific investigations. Notably, Iowa law does not mandate a specific dollar threshold for the amount of data compromised to trigger notification, nor does it require notification to the Iowa Attorney General unless the breach affects a substantial number of Iowa residents and the Attorney General requests it. The focus is on timely and informative communication to the individuals whose data has been exposed. This contrasts with some other states that might have different triggers or reporting requirements to state agencies.