CPPA Publishes NPRM for Data Broker Registration | Orrick, Herrington & Sutcliffe LLP

On July 5, the California Privacy Protection Agency (CPPA) issued an NPRM to adopt new regulations regarding the registration of data brokers to implement and enforce SB 362, known as the Delete Act (which InfoBytes writes about here).

The proposed regulations seek to clarify issues that data brokers have been grappling with since the CPPA first rolled out the data broker registration process in January this year by (i) spelling out the details of the registration fee, (ii) defining terms in the Delete Act such as “minor” and “direct relationship” to clarify which firms are data brokers, (iii) spelling out registration requirements for employees or agents of data brokers, and (iv) clarifying that every data brokerage firm is required to register, regardless of its parent or subsidiary status, among other things.

Public comments on the proposed rules must be received by August 20. In addition, a virtual public hearing will be held on the same day.