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Rhode Island

Rhode Island Data Transparency and Privacy Protection Act

Passed June 25, 2024
Effective Date January 1, 2026
Who it applies to

Entities that conduct business in Rhode Island or target Rhode Island residents, and during a calendar year either: 1) Control or process personal data of 35,000 or more Rhode Island residents; or 2) Control or process personal data of 10,000 or more residents and derive 20% or more of gross revenue from the sale of that data. Exemptions include entities and data regulated by GLBA, HIPAA-covered entities and business associates, nonprofits, institutions of higher education, state entities, data covered by FERPA, FCRA, DPPA, and national securities associations.

Penalties

The Rhode Island Attorney General enforces the RIDTPPA, treating violations as deceptive trade practices subject to fines up to $10,000 per violation. Additionally, intentional disclosures to shell companies or entities created to circumvent the law carry separate penalties ranging from $100 to $500 per disclosure. Notably, the RIDTPPA does not provide a cure period; penalties can be imposed immediately upon violation.

What’s notable about it:

Rhode Island’s RIDTPPA follows the Washington Privacy Act framework but features a unique privacy notice requirement. Only commercial websites and ISPs that collect, store, and sell personally identifiable information must disclose detailed data categories, all third-party recipients, and contact information. This narrow, prescriptive notice obligation raises practical challenges, especially around listing potential future data sales.

Unlike many state laws, RIDTPPA does not impose a general privacy notice obligation on all covered controllers, lacks a general data minimization requirement, and does not require recognition of universal opt-out signals like Global Privacy Control, limiting consumer opt-out convenience.

Finally, while its substantive provisions are weaker than many states’, Rhode Island’s law features relatively high penalties, up to $10,000 per violation plus additional fines for intentional disclosures, with no cure period. This mix of limited protections but strong enforcement creates a unique challenge for businesses needing to comply.

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