The Situation: California has enacted a groundbreaking new privacy law aimed at data brokers—entities that sell information about consumers with whom they do not have a direct relationship. Under the Delete Act (SB 362), data brokers must allow California consumers to delete their personal information through a “one-stop-shop” mechanism and must adhere to enhanced registration and transparency requirements.
The Result: Data brokers have to engineer their systems to process consumer deletion requests submitted through the “one-stop-shop” mechanism that the California Privacy Protection Agency (“CPPA”) will develop. Even if a data broker is registered under the existing California data broker registration law, the Delete Act requires new transparency disclosures about data broker practices.
