In what continues to be a busy year for genetic privacy developments, Rhode Island has joined the growing number of states regulating direct-to-consumer (“DTC”) genetic testing with its recently enacted genetic privacy law, S 2203. With S 2203, Rhode Island is the fifth state to enact genetic privacy legislation this year, following Utah, South Dakota, Connecticut, and Vermont. 

We previously analyzed S 2203 in full in a blog post here, and the final enacted version remains unchanged from our earlier analysis. The law took effect immediately.

Violations of the law are enforced exclusively by the Rhode Island Attorney General and may result in civil penalties of up to $1,000 for negligent violations and between $1,000 and $10,000 for willful violations, with penalties paid to the affected consumer.

Photo of Libbie Canter Libbie Canter

Libbie Canter represents a wide variety of multinational companies on managing privacy, cyber security, and artificial intelligence risks, including helping clients with their most complex privacy challenges and the development of governance frameworks and processes to comply with U.S. and global privacy laws.

Libbie Canter represents a wide variety of multinational companies on managing privacy, cyber security, and artificial intelligence risks, including helping clients with their most complex privacy challenges and the development of governance frameworks and processes to comply with U.S. and global privacy laws. She routinely supports clients on their efforts to launch new products and services involving emerging technologies, and she has assisted dozens of clients with their efforts to prepare for and comply with federal and state laws, including the California Consumer Privacy Act, the Colorado AI Act, and other state laws. As part of her practice, she also regularly represents clients in strategic transactions involving personal data, cybersecurity, and artificial intelligence risk and represents clients in enforcement and litigation postures.

Libbie represents clients across industries, but she also has deep expertise in advising clients in highly-regulated sectors, including financial services and digital health companies. She counsels these companies — and their technology and advertising partners — on how to address legacy regulatory issues and the cutting edge issues that have emerged with industry innovations and data collaborations.

Chambers USA 2026 ranks Libbie in Band 2 Nationwide for both Privacy & Data Security: Privacy and Privacy & Data Security: Healthcare.Chambers USA notes, Libbie is “incredibly sharp and really thorough. She can do the nitty-gritty, in-the-weeds legal work incredibly well but she also can think of a bigger-picture business context and help to think through practical solutions.”

Photo of Elizabeth Brim Elizabeth Brim

Elizabeth Brim provides strategic advice to clients across the health care, life sciences, digital health, and technology sectors, helping them navigate complex privacy, regulatory, and compliance issues involving health and other personal information.

Elizabeth advises clients on compliance with evolving privacy, data governance…

Elizabeth Brim provides strategic advice to clients across the health care, life sciences, digital health, and technology sectors, helping them navigate complex privacy, regulatory, and compliance issues involving health and other personal information.

Elizabeth advises clients on compliance with evolving privacy, data governance, and regulatory frameworks governing the collection, use, disclosure, and protection of health, genetic, consumer health, and other sensitive data. Her work includes counseling on HIPAA, state privacy laws, information blocking requirements, TEFCA, and other federal and state laws affecting health information, digital health technologies, and privacy compliance more broadly.

Elizabeth’s experience spans a broad range of privacy, data governance, cybersecurity, and regulatory issues arising in connection with innovative products and services, artificial intelligence and other emerging technologies, clinical trials and research initiatives, strategic transactions, and commercial arrangements. She regularly advises clients on complex issues involving data governance, privacy compliance, and the protection and exchange of health and other sensitive information.

Elizabeth also advises clients on related health care regulatory and compliance matters, including fraud and abuse, corporate practice of medicine, and other requirements affecting innovative care delivery models.

Elizabeth maintains an active pro bono practice, which includes assisting nonprofit entities with data privacy compliance and vendor contracting.

Elizabeth is an author of the American Health Law Association treatise, Pricing, Market Access, and Reimbursement Principles: Drugs, Biologicals and Medical Devices and the U.S. chapter of the Global Legal Insights treatise, Pricing & Reimbursement Laws and Regulations.

Photo of Clare Mathias Clare Mathias

Clare Mathias is an associate in the firm’s Boston office. She is a member of the Data Privacy and Cybersecurity Practice Group and the Health Care Practice Group.

Clare advises clients on a wide range of privacy and health care issues, including compliance…

Clare Mathias is an associate in the firm’s Boston office. She is a member of the Data Privacy and Cybersecurity Practice Group and the Health Care Practice Group.

Clare advises clients on a wide range of privacy and health care issues, including compliance with federal health care regulations and U.S. state and federal privacy laws.

Clare also maintains an active pro-bono practice.