Skip to content
Scan your site free

IOWA / CHAPTER 715D

IN FORCE

Iowa Consumer Data Protection Act (Iowa Code Chapter 715D) Reference Guide

Iowa residents can opt out of the sale of their personal data. Covered companies also have duties concerning notices, security, sensitive data and requests. The website’s privacy choice should reach the scripts and partners involved in an actual data sale.

Iowa defines sale as a transfer for monetary consideration. Its law requires targeted-advertising disclosure but does not create the same broad targeted-advertising opt-out right found in some states. This page separates those duties so a tag observation is not mistaken for a legal conclusion.

What is the Iowa Consumer Data Protection Act?

Iowa Code chapter 715D, the state’s Consumer Data Protection Act, took effect January 1, 2025. It grants qualifying residents access, deletion, portability and an opt-out of sale of personal data. Covered controllers also must provide notices, safeguard data and offer a clear notice and opt-out opportunity before processing sensitive data for a nonexempt purpose. Iowa Code: consumer rights Iowa Code: controller duties 2023 enrolled act: effective date

Website testing can document cookies, scripts and requests after an opt-out. A legal sale under Iowa’s statute requires monetary consideration and has listed exceptions; an advertising request by itself does not prove one. Iowa Code: definitions

Iowa privacy law at a glance

FieldIowa rule
LawIowa Consumer Data Protection Act, Iowa Code chapter 715D
StatusIn force since January 1, 2025
Threshold A100,000 or more consumers’ personal data in a calendar year
Threshold B25,000 or more consumers’ data plus over 50% of gross revenue from sale of personal data
ConsumerIowa resident acting in an individual or household context, subject to statutory exceptions
Sale definitionExchange of personal data for monetary consideration to a third party, with exceptions
Express opt-out rightSale of personal data; not a general right to opt out of targeted advertising or profiling
Targeted advertisingConspicuous disclosure and instructions regarding the sale opt-out; review the statute’s separate wording
Universal browser signalNo express universal GPC-recognition mandate in chapter 715D
Sensitive dataClear notice and opportunity to opt out before nonexempt processing; COPPA rules for known children
Consumer request90 days to respond; one justified 45-day extension
EnforcementIowa Attorney General; 90-day written notice and cure, then up to $7,500 per violation
Iowa Code Chapter 715D key law facts
Law
Iowa Consumer Data Protection Act, Iowa Code chapter 715D
Status
In force since January 1, 2025
Threshold A
100,000 or more consumers’ personal data in a calendar year
Threshold B
25,000 or more consumers’ data plus over 50% of gross revenue from sale of personal data
Consumer
Iowa resident acting in an individual or household context, subject to statutory exceptions
Sale definition
Exchange of personal data for monetary consideration to a third party, with exceptions
Express opt-out right
Sale of personal data; not a general right to opt out of targeted advertising or profiling
Targeted advertising
Conspicuous disclosure and instructions regarding the sale opt-out; review the statute’s separate wording
Universal browser signal
No express universal GPC-recognition mandate in chapter 715D
Sensitive data
Clear notice and opportunity to opt out before nonexempt processing; COPPA rules for known children
Consumer request
90 days to respond; one justified 45-day extension
Enforcement
Iowa Attorney General; 90-day written notice and cure, then up to $7,500 per violation

A tag can create a useful audit lead without proving a monetary sale. Iowa’s statutory rights must be read on their own terms.

01 / APPLICABILITY

Iowa has two coverage routes.

A person doing business in Iowa or offering products or services targeted to its residents is within chapter 715D when, in a calendar year, it processes data of at least 100,000 consumers. An alternative covers at least 25,000 consumers plus more than 50% of gross revenue from selling personal data. The second path needs both conditions. Iowa Code: § 715D.2

The law excludes certain entities and categories of information, including specified government, financial, health, nonprofit and higher-education contexts. The legal team must decide how these apply to the organization and each relevant data flow. Iowa Code: scope and exemptions

Sessions do not equal statutory consumers

Use the business’s calendar-year consumer count and sale-derived revenue. Website traffic by itself does not establish either threshold.

02 / RIGHTS AND DUTIES

The express opt-out right is for sales.

A qualifying Iowa resident may confirm and access personal data, delete data the resident provided, obtain a portable copy of certain provided data, and opt out of the sale of personal data. The law does not enumerate a general right to correct data or to opt out of targeted advertising and profiling in its rights section. A controller ordinarily has 90 days to respond, with one 45-day extension when justified and timely explained. Iowa Code: § 715D.3

Before nonexempt sensitive-data processing, Iowa requires clear notice and an opportunity to opt out. Known children’s sensitive data is handled under COPPA. Controllers also need reasonable security, a clear privacy notice, a secure request route and disclosures about sale or targeted advertising. Iowa Code: § 715D.4

Resident rights

  • Confirm and access covered data
  • Delete data provided by the consumer
  • Receive certain provided data in portable form
  • Opt out of monetary sales
  • Appeal a refusal to act

Controller duties

  • Disclose processing and recipients
  • Provide a sale opt-out route
  • Disclose targeted advertising
  • Give sensitive-data notice and opt-out opportunity
  • Secure data and govern processors
90 DAYS

Initial consumer-request response

+45 DAYS

One justified extension with notice

60 DAYS

Response to an appeal

Iowa Code: § 715D.3

03 / WEBSITE TRACKING

Monetary consideration matters to a sale finding.

Iowa defines a sale as an exchange of personal data to a third party for monetary consideration, with listed exclusions for processors, affiliates, requested services and other circumstances. A continuing ad request after an opt-out is something to examine, but it is not automatically an Iowa statutory sale. Iowa Code: § 715D.1

The statute defines targeted advertising and requires a conspicuous disclosure when a controller engages in it. Its consumer-rights section, however, expressly names a sale opt-out, not a general advertising opt-out. Counsel should examine recipients, payments, contracts and the purpose of each flow before assigning an Iowa violation. Iowa Code: § 715D.4(6) Iowa Code: § 715D.3(1)(d)

Observe the actual sale opt-out

  1. Inventory scripts, cookies and downstream recipients.

  2. Review payment terms and processor arrangements with counsel.

  3. Submit the site’s sale opt-out as a consumer would.

  4. Observe which data still leaves each tested page.

  5. Repair any classified flow that ignores the choice.

  6. Retest and keep the evidence.

04 / DIRECT REQUESTS AND GPC

Do not invent an Iowa GPC mandate.

Chapter 715D requires a secure and reliable route for consumer rights, including the sale opt-out. It does not expressly require every controller to recognize a universal Global Privacy Control browser signal. A multistate business may choose to honor GPC across jurisdictions; that is a separate architectural choice. Iowa Code: § 715D.4(7) Iowa Code: § 715D.3

Test consent rejection and GPC in separate browser sessions, then compare the results. For Iowa-specific proof, also test the site’s actual direct sale opt-out and document what happened to flows classified as sales.

  1. Iowa resident submits a sale opt-out
  2. Site records the request
  3. Relevant systems receive it
  4. Classified sale flows respond
  5. Post-choice requests are reviewed

Questions for the engineering review

  • Which sale opt-out method did the site offer?
  • Was the request completed and recorded?
  • Did the decision reach hard-coded code and tag manager?
  • Did a monetary sale flow continue afterward?
  • Which other laws apply to the same site?

05 / ENFORCEMENT

Iowa provides 90 days to cure after notice.

The Iowa Attorney General has exclusive enforcement authority. Before filing an action, the Attorney General must provide 90 days’ written notice identifying the alleged violation. If the business cures and gives the required written assurance, no action is initiated for that violation. A continued or renewed violation can lead to an injunction and a civil penalty of up to $7,500 per violation. Iowa Code: § 715D.8

  1. 2023

    Senate File 262 established chapter 715D. Iowa enrolled act

  2. January 1, 2025

    Chapter 715D became effective. Iowa enrolled act: § 10

  3. When an alleged violation is noticed

    A 90-day written notice-and-cure process precedes an Iowa Attorney General action. Iowa Code: § 715D.8

06 / PREPARATION

Classify each recipient before changing tags.

Your legal team decides whether the company is covered, which transfers count as monetary sales, and what other duties apply. The technical team implements that classification across direct scripts, tag manager and downstream vendors.

Your legal and privacy team’s scope

  • Coverage thresholds and exemptions
  • Monetary sale and recipient classification
  • Notices, consumer-rights and appeals
  • Sensitive data and children
  • Contracts and organizational governance

Your technical team’s scope

  • Map cookies, scripts and endpoints
  • Test the direct sale opt-out path
  • Check GPC for multistate consistency
  • Implement approved tag suppression
  • Retest and document the result

A practical Iowa sequence

  1. Confirm Iowa scope and exceptions.

  2. Map each transfer and its consideration.

  3. Identify flows subject to the sale opt-out.

  4. Apply the website choice across relevant systems.

  5. Review remaining post-choice traffic.

  6. Retest and preserve the evidence.

07 / TECHNICAL VERIFICATION

How to document website tracking behavior.

Use separate browser sessions to compare the site’s initial behavior, its response to a direct opt-out, and its response to Global Privacy Control where relevant to your review. Record the page URL, test time, browser settings and exact choice made so the result can be reproduced.

Inspect cookies and network requests before and after each choice. Record which requests continue, their destinations and the controls involved. Browser evidence can help diagnose an implementation; it cannot establish statutory applicability, the legal purpose of every transfer or organization-wide compliance.

01

Request evidence

The control and state used for the test.

02

Transfer evidence

Cookies, scripts, recipients and requests observed.

03

Classification context

Contracts and consideration assessed by legal counsel.

04

Repair evidence

Repeat scan following an approved configuration change.

09 / FAQ

Iowa privacy law questions.

When did Iowa’s Consumer Data Protection Act take effect?

January 1, 2025. It is codified at Iowa Code chapter 715D. Iowa enrolled act: effective date

What businesses are covered by Iowa Code chapter 715D?

An Iowa business or business targeting Iowa residents that processes at least 100,000 consumers’ data in a calendar year, or at least 25,000 and earns more than 50% of gross revenue from selling personal data, subject to exemptions. Iowa Code: § 715D.2

Does Iowa provide a targeted-advertising opt-out right?

The enumerated consumer-rights section expressly grants an opt-out of sale of personal data. Iowa separately requires conspicuous disclosure when a controller engages in targeted advertising. Iowa Code: §§ 715D.3–715D.4

Does Iowa require Global Privacy Control recognition?

Chapter 715D does not expressly impose a universal GPC browser-signal mandate. It requires a secure, reliable route for consumer-rights requests. Iowa Code: § 715D.4(7)

What is a sale of personal data under Iowa law?

Exchange of personal data by a controller to a third party for monetary consideration, with listed exceptions. Iowa Code: § 715D.1

Does Iowa require opt-in consent for sensitive data?

The Iowa provision requires clear notice and an opportunity to opt out before nonexempt sensitive-data processing; known-child processing follows COPPA. It is not a general affirmative opt-in rule. Iowa Code: § 715D.4(2)

How long does a controller have to respond?

Within 90 days, with one justified 45-day extension and notice during the first 90 days. Iowa Code: § 715D.3(2)

What is the Iowa enforcement cure period?

The Attorney General gives 90 days’ written notice before suit. A timely cure plus the required assurance prevents an action on that noticed violation. Iowa Code: § 715D.8

Does every advertising pixel count as a sale in Iowa?

No. The statute defines sale using monetary consideration and excludes certain transfers. A pixel requires review of its data, recipient and business terms. Iowa Code: § 715D.1

Does a website scan report establish full Iowa compliance?

No. It documents technical behavior under tested conditions. Scope and broader legal duties require independent assessment.

10 / PRIMARY SOURCES

Sources and editorial method.

This guide uses the Iowa Legislature’s 2026 codified chapter and the enrolled bill for its effective date. It distinguishes the expressly stated sale opt-out from targeted-advertising disclosure.

  1. Iowa Code § 715D.1: definitions
  2. Iowa Code § 715D.2: scope
  3. Iowa Code § 715D.3: consumer rights
  4. Iowa Code § 715D.4: controller duties
  5. Iowa Code § 715D.5: processor duties
  6. Iowa Code § 715D.8: enforcement
  7. Iowa Senate File 262: enrolled act

Prepared by Etalon Editorial Team. Last reviewed September 27, 2026. Material corrections may be sent to contact@etalondata.com.

11 / SCOPE AND RESPONSIBILITY

Technical findings have a defined scope.

Etalon is not a law firm and does not provide legal advice. A passing scan or certificate does not guarantee that an organization satisfies every legal obligation.

Technical testing records website behavior. Your legal and privacy team remains responsible for thresholds, exemptions, transfer classification, disclosures, rights requests, contracts and governance.

OPTIONAL SUPPORTING TOOL

Using Spectra in a technical review

Etalon Spectra compares network requests and cookies across isolated consent states to identify tracking that continues after a visitor opts out.

It can support the evidence-gathering process described in this guide. Findings describe tested website behavior and do not determine whether an organization complies with the law.