California Data Broker Registration Requirements

In September 2019, the California State Legislature passed Assembly Bill No. 1202 ("A.B. 1202"), amending the California Consumer Privacy Act ("CCPA"). The amendment requires qualified businesses to register as data brokers with the California Attorney General on or before January 31, 2020. A.B. 1202 defines "Data Broker" as "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." (emphasis supplied).  A.B. 1202 carves out exemptions from the data broker registration requirement for most entities subject to regulation under the federal Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, and the Insurance Information and Privacy Protection Act, respectively.