California’s Data Deletion Law Imposes a Host of New Obligations on Data Brokers | Insights | Skadden, Arps, Slate, Meagher & Flom LLP
On October 10, 2023, California Gov. Gavin Newsom signed into law Senate Bill 362, also known as the Delete Act, allowing California residents to have their personal information deleted by all registered data brokers operating in the state through a single deletion mechanism. The Delete Act, which amends California’s existing Data Broker Registration law, will require data brokers to: The definition of “data broker,” which remains unchanged from the Data Broker Registration law, includes any “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.” The Delete Act largely incorporates other definitions of key terms, such as “consumer” (i.e., California residents), “sell” (i.e., exchange of personal information for monetary or any valuable consideration), and “personal information,” from the California Consumer Privacy Act (CCPA). “Direct relationship,” however, is not defined. For furt
On October 10, 2023, California Gov. Gavin Newsom signed into law Senate Bill 362, also known as the Delete Act, allowing California residents to have their personal information deleted by all registered data brokers operating in the state through a single deletion mechanism. The Delete Act , which amends California's existing Data Broker Registration law , will require data brokers to: Register with the California Privacy Protection Agency (CPPA) (instead of the California Attorney General (AG)). Make significant additional disclosures to the CPPA. Delete all personal information held about C
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