Washington compliance for cloud infrastructure users
Washington compliance for cloud infrastructure users
Research steps taken and summary of findings:Steps taken- Performed targeted web searches for Washington state laws, agency guidance, and procurement/cloud security policies relevant to cloud infrastructure users (searches focused on RCW statutes, Washington Attorney General guidance, WaTech/OCIO policies, WaTech cloud services, sector-specific guidance e.g., health/financial, and reputable legal summaries).
Searches covered material current through 2026-01-03.- Collected and compressed authoritative sources (WA Attorney General, RCW statutes, WaTech/WaState cloud pages and privacy framework documents), plus law-firm and university summaries to confirm interpretation and practical implications.Key findings (what Washington businesses and LLC founders who use cloud infrastructure need to know)1) Data breach notification (private sector): RCW 19.255 and the Washington Attorney General require breach notice to affected Washington residents "in the most expedient time possible" and no more than 30 calendar days after discovery when the breach is reasonably likely to cause harm.
If more than 500 Washington residents are affected, the Attorney General must be notified (within the same 30-day window) and updates provided as information becomes available. The law has an encryption/secure-data safe-harbor (no notice required if data were secured/unreadable). (See RCW 19.255 and AG guidance.)
Research steps taken and summary of findings:Steps taken- Performed targeted web searches for Washington state laws, agency guidance, and procurement/cloud security policies relevant to cloud infrastructure users (searches focused on RCW statutes, Washington Attorney General guidance, WaTech/OCIO policies, WaTech cloud services, sector-specific guidance e.g., health/financial, and reputable legal summaries).
Searches covered material current through 2026-01-03.- Collected and compressed authoritative sources (WA Attorney General, RCW statutes, WaTech/WaState cloud pages and privacy framework documents), plus law-firm and university summaries to confirm interpretation and practical implications.Key findings (what Washington businesses and LLC founders who use cloud infrastructure need to know)1) Data breach notification (private sector): RCW 19.255 and the Washington Attorney General require breach notice to affected Washington residents "in the most expedient time possible" and no more than 30 calendar days after discovery when the breach is reasonably likely to cause harm.
If more than 500 Washington residents are affected, the Attorney General must be notified (within the same 30-day window) and updates provided as information becomes available. The law has an encryption/secure-data safe-harbor (no notice required if data were secured/unreadable). (See RCW 19.255 and AG guidance.)
Definition and scope of "personal information"
Washington’s statute defines personal information broadly (e.g., name + SSN, driver’s license, account numbers with security codes, full DOB, private keys, medical information, biometric data, and credentials). This expansive definition affects what incidents trigger notice obligations.
State agencies and cloud
Washington law and policy direct state agencies toward cloud and shared platforms. RCW 43.105.375 states agencies shall locate existing and new IT investments in the state data center or in commercial cloud services (with narrow waiver exceptions). WaTech (Washington Technology Solutions) operates state cloud landing zones (Azure/AWS) with baseline compliance mappings (e.g., NIST SP 800-53 Rev. 5, HIPAA) and expects customers to maintain responsibilities (provisioning, application configuration, and compliance with security standards). Agencies and vendors must use documented data-sharing agreements (DSAs) and follow the Washington State Agency Privacy Principles and OCIO/Privacy Framework.4) Health data (state-level): Washington’s My Health My Data Act (HB 1155, 2023) creates state-level protections for personal health data that fall outside HIPAA. It places obligations on regulated entities (consent, minimization, processor contracts, security), includes enforcement under the Washington Consumer Protection Act, and has staged effective dates (section 10 from July 23, 2023; sections 4–9 effective March 31, 2024 for non-small businesses and June 30, 2024 for small businesses). This affects any cloud-hosted health/fitness app data or health-adjacent data outside traditional covered-entity contexts.5) Frameworks and procurement expectations: WaTech and OCIO materials reference and map to NIST (including NIST Privacy and NIST 800-53), and WaTech public-cloud offerings indicate enterprise landing zones configured to support compliance (examples: NIST 800-53 Rev.5, HIPAA). State procurement and agency contracts commonly require DSAs, security terms, and vendor due diligence; state enterprise policies (privacy framework, OCIO policy references) instruct agencies to enter DSAs when sharing Category 3+ data. While FedRAMP or SOC2 may be required or strongly preferred depending on the agency, WaTech landing zones list built-in compliance monitoring and audit mode for multiple compliance offerings.6) Practical compliance steps for Washington businesses/LLCs using cloud infrastructure (synthesized from the statutes and state guidance):- Map data and classify (identify where Washington residents’ personal data and health data live).- Treat Washington’s breach-notice timeline (30 days) as mandatory for incidents likely to cause harm; prepare incident response and notification templates that meet RCW content requirements.- Use encryption and tokenization to limit notification triggers (ensure keys are protected) and implement strong key management.- Vendor due diligence: require DSAs / cloud contracts that include security controls, breach cooperation, data location, subcontractor/subprocessor obligations, audit rights, and incident timelines consistent with RCW and HB 1155.- For health-related data outside HIPAA, implement HB1155 obligations (consent, opt-in sharing rules, processor contracts, data-minimization) and update privacy notices and data subject rights processes.- Adopt NIST-based controls, logging, monitoring, and evidence of controls (SOC2/FedRAMP attestation where appropriate) to meet state agency expectations and for procurement competitiveness.- For contracted work with state agencies, review RCW and WaTech/OCIO requirements (DSAs, use of state cloud/landing zones, waiver processes) early in procurement.Conclusion and next steps for content generation- I gathered authoritative statutes (RCW 19.255, RCW 43.105.375), WA Attorney General guidance on breaches and the My Health My Data Act (HB1155), WaTech cloud and privacy resources, and legal summaries that confirm interpretation. This set of sources supports writing a comprehensive blog post and newsletter content tailored to US business owners/LLC founders on "Washington compliance for cloud infrastructure users," including practical checklists and state-specific requirements.If you want, I can now: (A) produce the full blog post + newsletter draft (with SEO meta and excerpt) using these sources, or (B) continue researching specific topics (e.g., sample DSA contract clauses for Washington, AG enforcement cases, or FedRAMP/SOC2 procurement thresholds). Tell me which you prefer.
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