If your company has received a consumer data request from a Colorado resident, you need to understand what the law requires, how quickly you must respond, and what information must be redacted before you send the response. This guide covers the Colorado Privacy Act (CPA) in practical terms — what it means for your business, not just what the statute says.
These requests are formally known as Data Subject Access Requests (DSARs) under European law, or consumer privacy requests under U.S. state law. Regardless of the terminology, the obligation is the same: locate the consumer's personal data, review it, redact third-party personal information, and respond within the statutory deadline.
For a comparison of all US state privacy laws, see our comprehensive comparison page. For state-specific guidance, see our guides for California, Virginia, Connecticut.
The Colorado Privacy Act (CPA) (Colo. Rev. Stat. §§ 6-1-1301 through 6-1-1313) took effect on July 1, 2023.
Applicability thresholds: Conducts business in Colorado or produces products or services targeted to Colorado residents, AND either: (a) controls or processes personal data of 100,000 or more Colorado consumers per calendar year, OR (b) controls or processes personal data of 25,000 or more Colorado consumers and derives revenue or receives a discount on goods or services from the sale of personal data.
Exemptions: State and local government entities, nonprofits, institutions of higher education, HIPAA-covered entities, GLBA-covered financial institutions, employers processing employee data in the employment context, and air carriers.
Physical presence: No physical presence required.
Practical note: If you are unsure whether your business meets the thresholds, consult with your legal team. The penalties for non-compliance are significant, and "we didn't know the law applied to us" is not a recognized defense.
Under the CPA, Colorado consumers have the following rights regarding their personal data:
Colorado was the first state to require recognition of universal opt-out mechanisms, effective July 1, 2024. The Colorado AG has issued specific technical specifications for compliance with universal opt-out signals. Sensitive data requires opt-in consent.
You have 45 calendar days from receipt of the request to provide a substantive response.
Extensions: One additional 45-day extension if reasonably necessary, with notice to the consumer.
When the clock starts: Upon receipt. Must verify identity using commercially reasonable methods.
If declining a request, the controller must provide the reason and instructions for appeal. The controller must respond to an appeal within 45 days.
Critical point: The deadline runs from when you receive the request, not from when you finish verifying the consumer's identity. Do not wait to begin processing until verification is complete — start locating and reviewing the data immediately.
When you compile documents for a consumer data request response, you will inevitably find personal information belonging to other people — colleagues, clients, family members, business contacts. This third-party data must be redacted before you send the response to the requesting consumer.
Some categories of information require case-by-case assessment:
The entire point of a consumer data request is to give the individual access to their own data. Do not redact the requester's personal information. This includes their name, email, phone number, address, employment records, transaction history, and any other data that relates to them specifically.
This is what makes data request redaction different from standard document redaction. You are performing selective redaction: keeping one person's data while removing everyone else's. Automated tools that simply blank out all PII will over-redact and produce an unusable response.
Penalties: Violations treated as deceptive trade practices under the Colorado Consumer Protection Act — penalties up to $20,000 per violation, among the highest in the United States.
Enforcement: Colorado Attorney General and Colorado district attorneys. No private right of action.
Cure period: The original 60-day cure period expired on January 1, 2025. The AG now has discretion.
The Colorado AG issued enforcement guidance in 2024 focused on universal opt-out mechanism compliance and has initiated investigations into businesses that fail to recognize opt-out signals.
Risk note: Even where a cure period exists, it typically applies only to the first violation. A pattern of non-compliance or a failure to cure within the allowed period can result in full penalties. The cost of responding correctly the first time is significantly lower than the cost of enforcement.
SafeRedact automates the most time-consuming part of responding to consumer data requests: identifying and redacting third-party personal information across thousands of documents.
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