Iowa Consumer Data Protection Act, sensitive data and biometric data definitions

A citation is an address, not a summary. The first part names the law; what follows narrows it to the exact section, article or paragraph.

What follows is LexLint's own research summary of this law, not legal advice.

In force since 1 January 2025.

A sensitive categories rule binding private bodies.

As of 27 August 2026.

What it requires

Offer an Iowa consumer an opt-out mechanism before processing their sensitive data. Unlike most peer states in this batch, ICDPA does not require opt-in consent for this category.
Do not treat an identifier derived solely from a photograph, video, or audio recording as ICDPA biometric data. The definition excludes any data generated from such a recording, with no exception for data generated to identify someone.

What it reaches

Excludes recording-derived identifiersYes

What this law does

Drafted with AI from the cited sources under the direction of UnGovr staff. UnGovr holds editorial responsibility for this page.

ICDPA classifies data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status (with a discrimination-avoidance carve-out not seen in the other six states in this batch), the processing of genetic or biometric data to uniquely identify a person, a known child's data, and precise geolocation data as sensitive data, but requires only an opt-out mechanism for sensitive-data processing rather than the opt-in consent every other state in this batch requires.

Genetic or biometric data collected to identify a person is itself an enumerated sensitive-data category (§ 715D.1(26)(b)), so biometric data is a heightened category here.

Separately, 'Biometric data' (§ 715D.1(4)) carries the same blanket, unconditional exclusion for recording-derived data as Virginia's VCDPA, word for word: no clawback for data generated to identify someone, so a voiceprint or faceprint extracted from a recording is not biometric data under ICDPA regardless of purpose, and therefore is not sensitive data either. These definitions sit at § 715D.1, not at § 715D.2, which is a different section (Scope and exemptions).

When LexLint raises it

processes_biometrics
processes_voice
crawls_web
trains_models

Read the law

official Iowa statute text, Iowa Code chapter 715D

Every line above is drawn from the primary source linked here, read on the date shown. This is a research summary, not legal advice.

Back to the example · Lint your app