Iowa's Consumer Data Protection Act (ICDPA), signed by Governor Kim Reynolds on March 28, 2023, became effective January 1, 2025. Iowa's law is modeled closely on Virginia's CDPA and is considered relatively business-friendly compared to states like California and Oregon. Notable features include a 90-day cure period (longer than most states' 30-60 days), no requirement to honor universal opt-out signals, and no right to appeal denied requests — though the law does provide all core consumer rights including access, deletion, portability, and opt-out of sale and targeted advertising. Iowa also does not require data protection assessments for high-risk processing activities.
Residents of Iowa have the following legally enforceable privacy rights under ICDPA:
Confirm whether a business processes your personal data and obtain a copy in portable format.
Request correction of inaccurate personal data held about you by covered businesses.
Request deletion of personal data you've provided or that has been collected about you.
Receive your personal data in a machine-readable, portable format to transfer to other services.
Prevent businesses from selling your personal data to third parties for commercial purposes.
Stop businesses from using your data to show you personalized ads based on your online behavior.
Opt out of automated decision-making used in significant decisions about credit, employment, or housing.
Businesses cannot penalize you with higher prices or reduced service for exercising your rights.
The ICDPA applies to controllers that conduct business in Iowa or produce products or services targeted to Iowa residents AND that during a calendar year control or process personal data of at least 100,000 consumers, or derive over 50% of gross revenue from the sale of personal data and control or process personal data of at least 25,000 consumers. The law contains broad exemptions for financial data covered by GLBA, health data covered by HIPAA, employment and business contact data, and publicly available information.
Under ICDPA, the following categories are classified as sensitive personal data and require explicit opt-in consent before processing:
Racial or ethnic origin · Religious or philosophical beliefs · Mental or physical health diagnoses · Sexual orientation or gender identity · Citizenship or immigration status · Genetic or biometric data uniquely identifying a person · Personal data of known minors · Precise geolocation data (within 1,750 feet)
Under ICDPA, businesses must respond to consumer rights requests within 45 days of receipt. This may be extended by an additional 45 days with prior written notice explaining the reason for the delay. Businesses must also establish an internal appeals process for denied requests, with a response due within 60 days.
The Iowa Attorney General has exclusive enforcement authority. Businesses must receive a 90-day written notice and opportunity to cure before the AG may pursue civil penalties — the longest cure period of any state privacy law. After the cure period, the AG may seek civil penalties up to $7,500 per violation. There is no private right of action.
To exercise your rights under ICDPA, contact the business through their official privacy portal (typically linked at the bottom of their website under "Privacy" or "Your Privacy Rights"). Clearly state:
1. That you are a Iowa resident invoking rights under ICDPA
2. Your full name and contact information linked to your account
3. The specific right you are invoking (access, deletion, opt-out of sale, etc.)
4. The legal deadline for response (45 days)
If the company denies your request, you have the right to appeal. If the company does not respond or appeal fails, you may file a complaint with the Iowa Attorney General's office.
| Term | Definition Under ICDPA |
|---|---|
| Personal Data | Any information linked or reasonably linkable to an identified or identifiable natural person. Does not include de-identified data or publicly available information. |
| Controller | A natural or legal person that, alone or jointly with others, determines the purposes and means of processing personal data. |
| Processor | A natural or legal person that processes personal data on behalf of a controller (e.g., a cloud hosting vendor). |
| Sale of Personal Data | The exchange of personal data for monetary or other valuable consideration by the controller to a third party. |
| Targeted Advertising | Displaying ads selected based on personal data obtained from a consumer's activities across non-affiliated websites or applications. |
| Profiling | Automated processing to evaluate, analyze, or predict aspects of a consumer's economic situation, health, personal preferences, behavior, location, or movements. |