California's Amended Data Broker Registration Law

In October 2023, California Governor Gavin Newsom signed Senate Bill (S.B.) 362 into law, amending California's data broker registration law. By January 31, 2024, qualifying data brokers must register with the California Privacy Protection Agency ("Agency"), and report certain additional information by July 1. Failure to comply may result in administrative fines or other costs. The following alert summarizes notable reporting and registration changes, and what action items qualifying organizations should take.

When do the amendments apply?

The amended law has been effective since January 1, 2024.

To whom do the amendments apply?

The previous law, as amended, applies to a "data broker," which 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."¹ Notably, the amended law removed the definition of "business," and now expressly incorporates the