Using Cookiebot for CTDPA compliance (Cookiebot Admin)

If you are already using Cookiebot CMP for GDPR and ePR compliance, follow the guide below to set up your CTDPA configuration and then see this article on how to set up coexisting configurations on your website to be displayed depending on the visitor's location.

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CTDPA: An introduction

What is CTDPA?

The Connecticut Data Privacy Act (CTDPA) operates based on the consumer right to opt-out of having personal data processed for the purposes of targeted advertising, profiling for decisions that could affect the consumer in a legal or similarly significant way and/or sale. It also requires companies and organizations to obtain the prior consent from end-users if they collect or process sensitive personal data, which we will take a deeper look at below.

This is similar to the EU's General Data Protection Regulation (GDPR) that has been in effect since 2018.

From January 1, 2023, websites, companies, and organizations who conduct business in Connecticut or produce products or services targeted to Connecticut residents and control or process personal data of 100,000 or more consumers during a calendar year, or control or process personal data of 25,000 or more consumers and derive over 50 percent of their gross revenue from the sale of that personal data must comply with the CTDPA's requirements.

What is personal data under CTDPA?

The CTDPA defines "personal data" as any information that is linked or reasonably linkable to an identified or identifiable natural person (de-identified data or publicly available information is exempt). The CTDPA also distinguishes between "personal data" and "sensitive personal data", the latter includes data from users under the age of 13, health and biometric data, geolocation data and data about racial or ethnic origin, religious beliefs, political convictions, and sexual orientation.

Who is required to comply with the CTDPA?

The CTDPA applies to companies or for-profit organizations doing business in Connecticut or that produces products and services for Connecticut residents. If you have a for-profit company located outside of Connecticut but you have users from inside Connecticut (e.g. by offering online services that Connecticut residents use), you are also required to be compliant with the CTDPA.

How to be compliant with Connecticut law?

Users must have the option to opt out of personal data being used for so-called targeted advertising.

Targeted advertising is when websites and companies use personal data to tailor marketing campaigns to the users, and is defined in the CTDPA as advertising that is "selected based on personal data obtained from a consumer's activities over time and across nonaffiliated websites or online applications to predict such consumer's preferences or interests."

In other words, under the Connecticut Data Privacy Act (CTDPA), users inside Connecticut must be enabled to opt out of cookies and trackers on websites that collect personal data for the purpose of targeted advertising.

This is usually done through a Consent Management Platform (CMP) that automatically detects cookies and controls them based on the consent state of users, as they navigate a consent banner on the website they visit.

CTDPA: A Cookiebot checklist

This guide is focusing solely on providing the tools needed to make your website's use of cookies and online tracking compliant with CTDPA. Other aspects of the CTDPA are therefore not covered or addressed in the checklist.

The checklist is not intended as legal advice - if in doubt, seek advice from a trusted legal source or your Data Protection Authority.

First time set up

If you are setting up Cookiebot for the first time, you can select the CTDPA preset at the very first step in the lower left portion of the screen.
This will automatically configure the banner to comply with CTDPA. You can still make some changes to suit your needs though.

Adding CTDPA as an additional legislation

When adding CTDPA as an additional legislation, you will need to create a separate domain group that is configured to comply with CTDPA.

Follow the following steps to create the additional domain group.

Add a new domain group.
- If you only have a single domain group:
  - Select "Domains & Aliases" from the left-hand menu.
  - Click "Manage your domain groups".
- If you already have multiple domain groups:
  - Click "Manage" at the top of the domain group section of the left-hand menu
- Click the "+ Create group" button.
Name your new domain group "CTDPA" and press the "Create group" button.
Click the "Configure CMP" icon on the line with your new domain group.
Click "Legislation presets" at the right side of the screen and select the CTDPA preset.