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The Minnesota Consumer Data Privacy Act Enacted

04 Jul



Update Applicable to:Effective date
All covered employersJuly 31, 2025

What happened?

On May 19, the Minnesota legislature passed the Minnesota Consumer Data Privacy Act (MNCDPA). The bill (HF 4757/SF 4782) moves to Governor Tim Walz for consideration.

What are the details?

The MNCDPA is similar to other comprehensive consumer privacy laws enacted in the United States. Here is how:

  • Application Thresholds: applies to entities that control or process the personal data of at least 100,000 Minnesota residents (excluding payment transaction data) during a year or derive over 25% of their gross revenue from selling personal data and process or control the personal data of at least 25,000 Minnesota residents.
  • Consumer Rights: gives individuals the right to personal data access, correction, deletion, and data portability. Individuals can also opt-out of the sale of their personal data and the processing of their personal data for targeted advertising.

However, the MNCDPA also includes several novel provisions that set it apart from other state privacy laws:

In the employer context, the bill excludes the employer-employee relationship from the consumer definition (Article 5, Section 3, (g), HF 4757):

(g) “Consumer” means a natural person who is a Minnesota resident acting only in an​ individual or household context. Consumer does not include a natural person acting in a​ commercial or employment context.

Business Considerations

  • Employers should identify their internal stakeholders who are responsible for data privacy compliance and create clear expectations and guidelines for them.
  • Employers should draft written policies that define their processes for data collection, organization, storage, and use.
  • Employers should review their third-party vendor contracts to ensure they comply with data privacy standards.
  • Employers must maintain a data inventory. This will be a record of the personal data they collect, where it is stored, with whom it is shared, and how it is protected.
  • Employers should practice data minimization, which means they should only collect and retain the minimum amount of personal data necessary to fulfill their stated purpose.
  • Employers should provide a comprehensive and up-to-date Privacy Policy.

Source References


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