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Signed Into Law
Signed May 24, 2025Effective 2025-09-01
SB1841

Regular Session

Relating to the confidentiality of certain information collected by certain local governments and airport governing boards.

Government Affairs & Regulatory Compliance Analysis

SB1841: Government Affairs Overview

SB1841 creates a statutory shield against public disclosure for customer data collected at Texas airports, specifically protecting parking, lounge, and retail transaction history from Texas Public Information Act (TPIA) requests. While this legislation protects your proprietary data from competitors, it requires you to actively reclassify data shared with airport authorities to ensure they do not inadvertently release it after September 1, 2025.

Sen. Nathan Johnson·Senate Bill·Regular Session

Low
Low Cost
Effective:2025-09-01
Enforcing Agencies

Local Government Airport Boards • Municipal Airport Departments • Texas Attorney General (Open Records Division)

Business Impact

Who SB1841 Affects

This legislation has regulatory implications for the following Texas businesses and organizations:

Regulatory Priority: low

Standard regulatory changes (effective 2025-09-01). Review during normal business planning.

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Transportation

Affected business types:

  • Trucking companies
  • Towing operators
  • Fleet operators
  • Logistics providers
View all transportation legislation

Key Operational Considerations

  • 1Public Information Officers (PIOs): If your staff assists airport authorities with TPIA responses, they must be retrained to redact these newly protected fields automatically.

Estimated Cost Impact

lowMinimal cost impact anticipated.

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SB1841
Low
Relating to the confidentiality of certain information collected by certain local governments and airport governing boards.
Low Compliance Urgency
Requires routine attention
Cost Impact
Low
Effective
2025-09-01
Enforcing Agencies
Local Government Airport BoardsMunicipal Airport DepartmentsTexas Attorney General
Primary Author: Sen. Nathan Johnson
89th Texas Legislature
jdkey.com
01

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

  • Effective Date: September 1, 2025
  • Compliance Deadline: August 31, 2025 (Data classification protocols must be active before the effective date to protect incoming requests).
  • Agency Rulemaking: No formal rulemaking required; however, the Texas Attorney General’s Open Records Division will likely issue opinions clarifying the scope of "profile names" as disputes arise in late 2025.

Immediate Action Plan

  • 1. Audit Data Feeds: Immediately identify all data points currently fed to Airport Authorities for revenue sharing or security purposes.
  • 2. Update Schemas: Tag all customer profile, parking, and lounge data as "Confidential" in your export systems by August 31, 2025.
  • 3. Notify the Authority: Send a formal notice to your Airport Contract Manager citing SB1841, explicitly instructing them to update their TPIA response protocols regarding your data.
  • 4. Review Insurance: Verify that Cyber Liability policies cover the specific data points now deemed confidential by state law (e.g., Trusted Traveler info).

Operational Changes Required

Contracts

  • Master Concession Agreements: Review agreements with Airport Boards (e.g., DFW, HAS, SAT). Issue a formal letter or contract addendum asserting that data shared for revenue verification is now statutorily confidential under SB1841 and must be withheld from public release.
  • Sub-Vendor Agreements: Update contracts with loyalty program managers and payment processors to reflect that Texas law now prohibits the public disclosure of this data, reinforcing liability if they mishandle it.

Hiring/Training

  • IT & Data Teams: Staff responsible for data transmission to government bodies must be trained to tag specific fields (lounge membership, travel dates, purchase history) as "Confidential – SB1841 Exempt" within database schemas.
  • Public Information Officers (PIOs): If your staff assists airport authorities with TPIA responses, they must be retrained to redact these newly protected fields automatically.

Reporting & Record-Keeping

  • Data Classification Policy: Update internal policies to categorize "Airport Customer Profile Data" as "Restricted/Confidential."
  • Exemption Logs: Ensure your legal team provides the Airport Authority with the specific statutory citations (Texas Transportation Code § 22.028 and § 22.091) to use in their exemption logs when denying requests for your data.

Fees & Costs

  • No New Fees: There are no statutory fees associated with this change.
  • Cost Savings: Potential reduction in legal costs previously associated with seeking injunctions to stop the release of trade secret data.

Strategic Ambiguities & Considerations

  • "Profile Name" Definition: The statute protects "profile names," but does not define if this applies to temporary guest profiles or only registered loyalty accounts. Until the AG issues an opinion, businesses should treat *any* customer identifier linked to a transaction as confidential.
  • Scope of "Airport Facility Use": The phrasing is broad and likely covers non-travelers (e.g., visitors parking to pick up passengers). Businesses should interpret this broadly to protect all consumer data generated on airport property, not just that of ticketed passengers.

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JD Key Consulting specializes in Texas regulatory compliance strategy. Work directly with James Dickey—former Chairman of the Republican Party of Texas—to understand this bill's impact on your operations and develop an actionable compliance plan.

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Information presented is for general knowledge only and is provided without warranty, express or implied. Consult qualified government affairs professionals and legal counsel before making compliance decisions.

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Legislative Timeline

This bill's path through the Texas Legislature

Filed
Mar 4, 2025
Passed Senate
Apr 10, 2025
Passed House
May 12, 2025
Signed
May 24, 2025
Effective
Sep 1, 2025
TopicsOpen RecordsProtection of Personal InformationTransportationTransportation--aviationAirportsParkingTravel
03

Senate Authors

Sen. Nathan JohnsonDemocrat · Primary Author
Coauthors (1)

House Sponsor

Rep. Yvonne DavisDemocrat · Primary Sponsor

Bill Text(with markup)

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

Related Legislation

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More from Sen. Nathan Johnson

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Related by Topic

View more Open Records legislation
Quick Reference

Frequently Asked Questions

Common questions about SB1841

Q

What does Texas SB1841 do?

SB1841 creates a statutory shield against public disclosure for customer data collected at Texas airports, specifically protecting parking, lounge, and retail transaction history from Texas Public Information Act (TPIA) requests. While this legislation protects your proprietary data from competitors, it requires you to actively reclassify data shared with airport authorities to ensure they do not inadvertently release it after September 1, 2025.

Q

Who authored SB1841?

SB1841 was authored by Texas Senator Nathan Johnson during the Regular Session.

Q

When was SB1841 signed into law?

SB1841 was signed into law by Governor Greg Abbott on May 24, 2025.

Q

Which agencies enforce SB1841?

SB1841 is enforced by Local Government Airport Boards, Municipal Airport Departments and Texas Attorney General (Open Records Division).

Q

How significant are the changes in SB1841?

The regulatory priority for SB1841 is rated as "low". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of SB1841?

The cost impact of SB1841 is estimated as "low". This may vary based on industry and implementation requirements.

Q

What topics does SB1841 address?

SB1841 addresses topics including open records, protection of personal information, transportation, transportation--aviation and airports.

Q

What are the key dates for SB1841?

Key dates for SB1841: Effective date is 2025-09-01. Consult with legal counsel regarding applicability.

Q

Which Texas businesses are affected by SB1841?

SB1841 primarily affects transportation and logistics companies. These businesses should review the legislation with their legal and compliance teams to understand potential impacts.

Need Strategic Guidance on This Legislation?

JD Key Consulting is an Austin, Texas-based government affairs firm led by James Dickey, former Chairman of the Republican Party of Texas. We specialize in Texas regulatory compliance and legislative strategy for data centers, energy, banking, and manufacturing.

Legislative data provided by LegiScanLast updated: January 11, 2026