Tennessee Information Protection Act (TIPA) Compliance: Key Steps for Businesses

July 1, 2025
Author: Rimsha Zafar

The data privacy landscape in the United States is shifting yet again, and businesses must keep up. Starting July 1, 2025, the Tennessee Information Protection Act (TIPA) takes effect, bringing major new requirements for companies handling consumer data in the state.

 

Are you wondering what this means for your business and how to stay compliant? You’re not alone. With stricter thresholds, expanded consumer rights, and rigorous enforcement actions, this law could significantly impact how you collect, store, and share data.

 

In this blog, we’ll break down who TIPA applies to, what it requires, the rights it grants to Tennesseans, and how your business can prepare to comply without unnecessary risk or confusion.

What is the Tennessee Information Protection Act (TIPA)?

Passed on May 11, 2023, and going into effect on July 1, 2025, the Tennessee Information Protection Act (TIPA) is a comprehensive data privacy law designed to protect residents’ personal information and set clear rules for businesses. It aims to balance consumer rights with responsible data practices.

 

TIPA aligns with several other U.S. state privacy laws—such as those in Virginia and Utah—but takes a more structured and accountability-driven approach in key areas. It provides a clear framework that businesses can adopt to ensure privacy compliance while offering consumers meaningful control over their personal data.

Who Does TIPA Apply To?

Applicability Criteria

 

TIPA doesn’t apply to every business—only those that meet specific size and data-processing thresholds. It applies to businesses that generate over $25 million in annual revenue and process the personal data of either:

 

  • 175,000 or more Tennessee consumers per year, or
  • 25,000 or more consumers while deriving 50% or more of gross revenue from selling personal data.

 

If your business meets these thresholds, it’s essential to act now to avoid penalties later.

 

Entities Exempt from TIPA Compliance

 

 

TIPA applies only to select entities—many organisations are exempt based on their nature and regulatory status:

 

  • Government agencies
  • Nonprofit organisations 
  • Financial and healthcare institutions governed by GLBA or HIPAA
  • Educational institutions under FERPA
  • Licensed insurance providers regulated in Tennessee

 

These exclusions help streamline enforcement and prevent overlap with existing sector-specific regulations.

Core Consumer Rights Under TIPA

TIPA grants Tennessee residents strong privacy rights, empowering them to control how their data is handled. Businesses must ensure these rights are easy to exercise.

 

Consumer Rights

 

TIPA empowers Tennessee consumers with several key rights to control their personal data. These rights ensure transparency and accountability from businesses. Key consumer rights include:

 

  • Right to access personal data collected
  • Right to correct inaccurate data
  • Right to delete personal data
  • Right to data portability, enabling users to obtain and transfer their data
  • Right to opt out of:
    • Targeted advertising
    • Sale of personal data
    • Profiling that results in legal or similarly significant outcomes
  • Right to appeal a denial of rights requests

 

Businesses must respect these rights and provide timely responses to consumer requests.

 

Timelines for Response

 

Businesses must respond to consumer requests within 45 days. A one-time 45-day extension is allowed if reasonably necessary, provided the consumer is informed.

What TIPA Requires from Businesses

Enhanced Privacy Disclosures

 

Businesses must publish clear and accessible privacy notices. These notices should explain why personal data is collected, what categories of data are gathered and shared, and how consumers can exercise their rights. Transparency in privacy disclosures helps build consumer trust and ensures compliance with TIPA. 

 

Handling Sensitive Personal Data

 

TIPA requires businesses to obtain explicit, opt-in consent before processing sensitive personal data. This includes biometric and health-related data, religious beliefs or ethnic origin, precise geolocation, and data belonging to children under 13. Obtaining user consent ensures respect for consumers’ privacy and aligns with regulatory expectations.

 

Mandatory Data Protection Assessments

 

The law mandates businesses to conduct data protection assessments for high-risk activities such as targeted advertising, selling personal data, processing sensitive information, and profiling that has significant legal effects. These assessments must be documented and reviewed regularly to maintain ongoing compliance and risk management.

 

Security and Governance Measures

 

Businesses must implement reasonable administrative, technical, and physical safeguards to protect personal data. Regular audits and updates to security measures are expected.

 

NIST Privacy Framework as a Safe Harbour

 

TIPA offers a unique incentive: businesses that adopt the National Institute of Standards and Technology (NIST) Privacy Framework gain a strong legal defence in case of enforcement.

Enforcement, Penalties, and Cure Period

TIPA is enforced solely by the Tennessee Attorney General. Unlike California’s law, there is no private right of action, meaning consumers cannot sue directly.

 

Key Enforcement Provisions:

 

  • A 60-day cure period allows businesses to fix any violations after receiving notice.
  • Failure to cure can result in fines of up to $7,500 per violation.
  • Willful violations may incur treble damages, significantly raising potential penalties.

 

This structured enforcement approach encourages compliance while providing businesses a fair chance to correct mistakes before penalties apply.

How TIPA Compares with Other State Privacy Laws

While TIPA shares similarities with laws in Virginia and Utah, several features make it unique:

 

  • Dual threshold requirement: Both revenue and data processing criteria must be met.
  • Extended cure period: Offers 60 days to resolve violations, longer than some other state laws.
  • Focus on national alignment: Strong encouragement to follow the NIST framework for added legal protection.

 

In contrast, California’s CCPA/CPRA allows for broader consumer lawsuits and has shorter response windows and no cure period.

How to Prepare for TIPA Compliance

With TIPA enforcement around the corner, businesses must take proactive steps. Here’s how to prepare:

 

1. Review and Update Privacy Policies

 

Ensure that your policies clearly state data usage purposes, data categories, and how consumers can assert their rights.

 

2. Implement a Rights Management System

 

Develop infrastructure to handle access, correction, deletion, and opt-out requests. This includes staff training and internal workflows.

 

3. Conduct Risk-Based Assessments

 

Perform and document assessments for any activity involving sensitive data, profiling, or data sales.

 

4. Align with NIST Frameworks

 

Adopt the NIST Privacy Framework to enhance compliance, improve internal governance, and reduce enforcement risk.

Final Thoughts

TIPA represents a major milestone in the evolution of U.S. privacy law. By offering strong consumer protections and a clear compliance path for businesses, Tennessee sets a model for practical and enforceable privacy regulation.

 

With just months to go, now is the time to assess your exposure and align your privacy practices with TIPA’s requirements. Delay could lead to steep penalties and loss of consumer trust. By preparing now, you can avoid compliance risks and build greater trust with your users.

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Frequently Asked Questions (FAQs)

What is the Tennessee Information Protection Act (TIPA)?

TIPA is Tennessee’s comprehensive privacy law, effective July 1, 2025. It regulates how businesses collect, process, and protect consumer data, granting residents rights over their personal information. It aligns with other U.S. state laws but includes distinct accountability and enforcement provisions.

Does TIPA apply to small businesses in Tennessee?

No. TIPA applies only to businesses making over $25 million annually and meeting specific consumer data thresholds. Small businesses that don’t process significant volumes of data or generate revenue from data sales are generally exempt from its requirements under current rules.

What consumer rights does TIPA guarantee?

TIPA grants residents rights to access, correct, delete, and port their personal data. Consumers can also opt out of targeted advertising, data sales, and profiling decisions, and appeal if their request is denied. Businesses must respond within 45 days of the request.

What are the penalties for violating TIPA?

Businesses have a 60-day window to fix any violations after notice from the Attorney General. If unresolved, penalties can reach $7,500 per violation. Willful or repeated violations may trigger treble damages, significantly increasing enforcement risks and potential legal consequences for noncompliant companies.

How can my business prepare for TIPA compliance?

Begin by updating your privacy policies and data practices. Implement a system to manage consumer rights requests, conduct risk assessments for high-impact data activities, and align with the NIST Privacy Framework for safer, more defensible data governance under Tennessee’s new requirements.

What makes TIPA different from California’s CCPA?

Unlike CCPA, TIPA doesn’t allow private lawsuits—only the state Attorney General can enforce it. TIPA also provides a longer 60-day cure period and emphasises the NIST Privacy Framework as a legal safe harbour, which California law does not currently recognise. 

 

Rimsha Zafar

Rimsha is a Senior Content Writer at Seers AI with over 5 years of experience in advanced technologies and AI-driven tools. Her expertise as a research analyst shapes clear, thoughtful insights into responsible data use, trust, and future-facing technologies.

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