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California changes disclosure rules for sexual orientation, gender identity, and intersex data

SB 1114 limits identifiable SOGISC disclosures by specified state entities and includes inference data, exceptions and staged implementation.

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What happened

The Governor signed SB 1114 on September 26 to change collection, use and disclosure of sexual-orientation, gender-identity and intersex/sex-characteristic information, or SOGISC. The named state entities include DHCS, CDPH, Social Services and other specified departments; this is not a universal direct collection rule for every private provider. The disclosure protection reaches information reasonably usable to infer transgender or intersex status, including specified marker records and medical information not otherwise protected by HIPAA or CMIA. Voluntary self-identification and statutory collection exceptions remain important, including the express limit on compelling providers or other third parties to supply information not voluntarily provided.

Identifiable disclosure outside California state or local government or its authorized agent is limited to listed exceptions, including mandatory federal/interstate participation terms, valid California-enforceable warrants or orders, public-health functions, protected necessary vendor services, the Information Practices Act and Civil Rights Department statutory work. Disclosures must be minimized. Shared-system separation has an entity-specific automation-notice trigger; Social Services has a separate January 2028 timing provision and CDPH’s stated third-party collection milestone is March 28, 2029. The act also creates a public-records confidentiality provision with deidentification/Information Practices Act exceptions and express vehicle-record/Civil Rights Department exclusions. The January 2027 effective date therefore does not make every provision operative for every data holder at once.

Scope and timing

Authority status
Final
Applicability
Directly applicable
Audience
Health systems, Provider networks
Jurisdiction
California
Recorded date
2027-01-01
Date type
effective

Why it matters

Data inventories must capture inferential information, permitted purpose and recipient, as well as the relevant agency and implementation trigger.

Sources

Complete edition and supplemental material

This finding in the complete approved report →

Regulatory horizons, CIA trends and implementation trackers remain in the full report.

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