79%
of Tennessee's 19 requirements are already met by California (CA). Here is what TIPA adds, biggest gaps first.
AppealsConsumers' rightsBig gap
CA0 No statutory appeal process for denied requests.
TIPA adds2 Internal appeal decided within 60 days; denial must give a way to complain to the Attorney General and Reporter.
Tenn. Code Ann. § 47-18-3203(c) · source ↗
Sensitive dataSensitive data and minorsGap
CA0 Broad sensitive personal information list, including neural data, IDs and financial log-ins; consumers get a right to limit use rather than opt-in consent.
TIPA adds1 Opt-in consent to process sensitive data (standard categories plus known child and precise geolocation).
Tenn. Code Ann. §§ 47-18-3201(26), 47-18-3204(a)(6) · source ↗
De-identified dataBusiness dutiesGap
CA2 Deidentified data requires reasonable measures, a public commitment not to reidentify, and contract flow-down to recipients.
TIPA adds3 Public commitment not to reidentify, contract duties for recipients, and pseudonymous data rules.
Tenn. Code Ann. § 47-18-3207 · source ↗
Maximum penaltyEnforcementGap
CA2 Up to $2,663 per violation and $7,988 per intentional violation or violation involving known minors under 16 (2025 adjusted).
TIPA adds3 Up to $7,500 per violation; court may award treble damages for willful or knowing violations.
Tenn. Code Ann. § 47-18-3212(d) · source ↗
Already covered by CA: Thresholds, Exemptions, Children and teens, Data minimization, Rights, Request deadline, Universal opt-out, Assessments, Processor contracts, Privacy notice, Loyalty programs, Who enforces, Cure period, Private action, Rulemaking.
A gap means TIPA is more demanding than CA on that requirement, on our 0 to 3 scale (how we score). Read the cited section before acting. Not legal advice.
