Venable partner Mike Signorelli presented “The New ‘Data Broker’ Conundrum: Expansive Views of Regulated Entities” at the DAA Summit 2025 on June 4.
What constitutes being a data broker these days? New laws and regulations seek to safeguard the personal data of Americans from access by foreign adversaries. The most recent of those regulations is the Department of Justice’s “Bulk Data Rule,” which prohibits access to certain data critical to data-driven advertising by countries of concern and other covered entities. In addition, certain states—and even other federal agencies—are taking an expansive view of data sales. How should marketing organizations, first parties included, navigate the commercial availability of customer data as definitions of data broker grow wider?
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