California Privacy Update—October 13, 2023

Governor Gavin Newsom in California recently signed several bills into law that may have a significant impact on your company's privacy compliance obligations. These new laws amend and build on existing California privacy laws, including the California Consumer Privacy Act (CCPA).

The Delete Act in particular will create difficult compliance obligations for companies that are currently subject to California's data broker registration law. The new law will not only increase the information that data brokers are required to provide as part of their annual registration (which will now need to be submitted to the California Privacy Protection Agency (CPPA) instead of the California Attorney General), but it will also require them to implement technical mechanisms to honor deletion and opt-out requests made by consumers to all data brokers on the registry. (Consumers will essentially have a "one-stop shop" with regard to deleting and opting out of certain uses of their