The California Consumer Privacy Act ("CCPA") is
expected to become operative on January 1, 2020 and will usher in a
new era of data privacy for consumers across the United States. The
CCPA establishes various rights for individuals, most notably the
right to know about the collection, sale, and disclosure of their
personal information, the right to opt-out of the sale of their
personal information, and – the subject of today's post
– a limited right to request that their personal information
be deleted.
Under Section 1798.105 of the CCPA, upon receipt of a
"verifiable consumer request," a business must
"delete the consumer's personal information from its
records" and direct all of its service providers to do the
same. And businesses must tell consumers about this right so they
know to invoke it. Easy enough, right? Not really.