With its draft rules, Colorado has set forth a new model for state privacy laws.  While there are many areas that are interoperable with the California model, the Colorado draft rules include important differences, as well as rules on topics that have been notably absent from California’s draft rules.  Ballard partners Phil Yannella and Greg Szewczyk discuss the highlights of the Colorado draft rules, differences with California, and practical steps for developing a comprehensive compliance plan for all of the upcoming 2023 laws.