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What 'data minimization' can mean: three state models and key questions for Vermont
Summary
Witnesses at the Vermont hearing described three state models for data minimization—procedural (disclosure‑tied), California's reasonable‑expectations approach, and Maryland's product/service‑linked standard—highlighting tradeoffs for consumer protection, enforcement, and business compliance.
Experts at the legislative hearing broke down three distinct approaches states have taken to data minimization and flagged interpretive questions Vermont lawmakers would need to answer.
Jordan Francis, senior policy counsel at the Future of Privacy Forum, framed the issue as three models. He called the most common approach "procedural data minimization," used by many states, where a controller limits collection to what is "adequate, relevant, and reasonably necessary in relation to the purposes disclosed to the consumer." That model ties what businesses can collect to the purposes they disclose.
Francis described California's current position,…
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