The scheme we imagined, as it relates to the private right of action, is this: The first finding of violation essentially allows people to proceed to court with a finding. It allows the court, essentially, to make the determination as to whether or not additional remedy is required or justified. It's supposed to be a short-circuiting in part, because there's already been a found violation by the entrusted, resourced entity the legislation holds responsible for making first-instance determinations of privacy violations. It's not the case in a private right of action scenario without that requirement.
On May 27th, 2024. See this statement in context.