Law note · United States

DOJ Data Security Program (Bulk Sensitive Personal Data Rule)

cite 28 CFR Part 202 stage In effect since 2025-04-08 reviewed 2026-08-23

Prohibits U.S. persons from engaging in data-brokerage transactions involving bulk U.S. sensitive personal data or government-related data with a country of concern or covered person, and restricts, subject to required security measures, vendor, employment, and investment-agreement transactions that would give such a country or person access to bulk sensitive personal data, including biometric identifiers such as facial images or voice prints collected on more than 1,000 U.S. persons, or human genomic data on more than 100.

What it asks of an app

  • Do not engage in a prohibited bulk data-brokerage transaction involving bulk U.S. sensitive personal data, including biometric identifiers such as facial images or voice prints, or government-related data, with a country of concern or covered person.
  • Apply the required security safeguards to a restricted vendor, employment, or investment transaction that would give a country of concern or covered person access to that data.

When LexLint raises it

Declared activities: crawls_web, trains_models, processes_biometrics, processes_voice

Primary source: Federal Register final rule text, via govinfo.gov

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