What Every Small and Mid-Size Business, Including Law Firms, Should Know About Texas SB 2610

When Texas Senate Bill 2610 took effect on September 1, 2025, it fundamentally changed how businesses manage personal data across the state.¹ Modeled after leading privacy frameworks such as the CCPA and GDPR, the law establishes new standards for transparency, consumer rights, and data protection.²

For small and mid-sized businesses, including law firms, the challenge lies in translating these broad legal requirements into actionable steps. Many of these organizations handle sensitive client and consumer data every day but often lack the robust compliance systems of larger corporations.³

Rising Expectations Around Privacy

SB 2610 grants Texans greater control over their personal information, including rights to access, correct, and delete their data.⁴ Businesses must now enable individuals to exercise these rights, and to opt out of targeted advertising or data sales where relevant.⁴ Organizations are also required to post clear privacy notices and to implement security safeguards that match their level of data risk.^{2 5}

For smaller businesses, these obligations raise questions about scalability and cost. Although the law applies primarily to Texas businesses with fewer than 250 employees that own or license computerized data containing sensitive personal information,³ ⁶ even those below statutory thresholds may be indirectly affected via contractual obligations imposed by clients or vendors who must meet stricter standards.⁷

Law firms face additional complexity because they must also comply with the Texas Disciplinary Rules of Professional Conduct, which emphasize confidentiality and require technological competence.⁸

What This Means for Law Firms

It’s no secret that legal professionals have long been entrusted with highly sensitive information. SB 2610 extends that duty into the digital world, where client data moves through email systems, case-management software, and cloud platforms. In many ways, the law raises the bar beyond traditional ethical obligations, ensuring that confidentiality evolves alongside modern technology.

At the same time, however, it tiers down certain business responsibilities. Critics argue that this shift represents a step backward in meaningful cybersecurity protection, yet for now, it’s the framework we have to work within.

To remain compliant, firms should assess their technology vendors to confirm they follow comparable privacy and security standards.7 Regularly reviewing privacy policies, data-sharing protocols, and breach response procedures should become part of every firm’s risk management process.^{5 8}

Ideally, though, we should be operating far beyond a mere “check-the-box” approach. A cyber incident today is more than just the risk of fines or regulatory penalties, it will directly affect client trust, professional credibility, and the long-term health of your practice.

Five Steps to Prepare Your Organization

1. Understand your data. Map what personal data you collect, where it resides, and how it is used.^{3 2}

2. Refresh your privacy notice. Make sure privacy notices (especially on websites and client forms) are concise and transparent.²

3. Evaluate vendor contracts. Include explicit privacy and data protection clauses in all third-party agreements.⁷

4. Establish an incident response plan. Ensure your organization can detect, contain, and report data breaches quickly, a requirement that now involves notifying the Texas Attorney General and affected consumers within 30 days.⁵

5. Train your staff. Promote cybersecurity and privacy awareness at every level of your organization.^{1 8}

Even if your business isn’t directly subject to SB 2610, applying these practices demonstrates accountability and builds trust with clients and partners who value data protection.^{9 2}

Beyond Compliance

Compliance is only one part of the equation. Businesses that treat privacy as a way to strengthen client trust can enhance both their reputation and competitive advantage.⁶ For law firms, a strong privacy posture signals professionalism, reliability, and ethical leadership in an increasingly digital world.^{8 2}

Texas has joined a national movement that frames privacy and security as business fundamentals, not optional extras. Organizations that adapt early will be in a stronger position for long-term success built on trust and transparency.⁶

Endnotes

1 Texas Senate Bill 2610 Full Text – Texas Legislature Online
https://capitol.texas.gov/BillLookup/Text.aspx?LegSess=89R&Bill=SB2610

2 Texas Data Security & Privacy Laws – The Beckage Firm
https://thebeckagefirm.com/texas/

3 SB 2610 Overview and Applicability – Palindrome Tech
https://palindrometech.com/governance-risk-management-compliance-resources/texas-legislation-sb-2610-cybersecurity-safe-harbor-for-small-businesses-what-you-need-to-know-and-steps-to-prepare

4 Navigating SB 2610 – Bridepoint Consulting
https://bridgepointconsulting.com/insights/sb-2610-navigating-2025-cybersecurity-ruling-texas-businesses/

5 SB 2610 Compliance for Texas Small & Mid-sized Businesses – Avatar Managed Services
https://avatarmanagedservices.com/texas-sb-2610-data-privacy-compliance/

5 Texas SB 2610: Cybersecurity Safe Harbor for Small and Mid-Sized Businesses – Spencer Fane
https://www.spencerfane.com/insight/texas-cybersecurity-safe-harbor-for-small-and-mid-sized-businesses/

7 Texas Comptroller Vendor Management Guidance
https://comptroller.texas.gov/purchasing/publications/procurement-contract.php

8 Technology & Confidentiality Rules for Attorneys – State Bar of Texas Blog https://blog.texasbar.com/2025/08/articles/guest-blog/ethical-ai-integration-for-texas-attorneys-a-practical-guide-to-confidentiality-data-privacy-and-export-controls/

9 SB 2610 Summary – Clear Guidance
https://www.clear-guidance.com/insights/texas-sb2610-reduced-liability-for-proper-cybersecurity