California strikes again -- and the Delete Act is here! 

The Delete Act requires the CPPA to create an “accessible deletion mechanism” where consumers can direct some or all data brokers to delete all of their information, subject to the same deletion and other exceptions available under CCPA (starting in 2026). A “data broker” is “a business that knowingly collects and sells to third parties the personal information of a consumer with whom the business does not have a direct relationship.” This will impact both data brokers and the companies that rely on those companies to enhance their information about and understanding of their audience.

Three key points I'm focused on. 

The Delete Act:
#1 - Requires data brokers to delete the personal information of a consumer who has submitted a request every 45 days (i.e. understanding that data sets are continually refreshed, brokers will be required to continually delete the consumer's data so it doesn't get reintroduced into their systems for future use)
#2 - Allows authorized agents to make this request (*although you can require consumer verification, if the identity can't be verified, the request must be treated as an opt-out of sale)
#3 - Requires data brokers to undergo independent compliance audits every three years (beginning in 2028)

We are discussing these issues and more this Thursday, at 2pm on LinkedIn Live.