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CPPA Enforces Data Broker Registration Under Delete Act

Data brokersOctober 30, 2024California Privacy Protection Agency

Summary

The California Privacy Protection Agency (CPPA) announced an investigative sweep to enforce data broker registration compliance under the Delete Act. Data brokers must register annually and pay fees, with penalties of $200 per day for non-compliance. The CPPA will take enforcement actions against unregistered data brokers and is developing a consumer deletion platform (DROP) for 2026.

Remedy

Data brokers must register with the CPPA by January 31 each year and pay the required annual fee. They must disclose deletion request metrics, report on collection of minors' data, reproductive healthcare data, and precise geolocation data, and provide a link to consumer rights information. Non-compliance incurs a $200 per day penalty that the CPPA will seek to recover.

Monetary PenaltyReporting Requirements

Contract Impact

In-house legal teams should review all agreements where their company acts as a data broker (selling personal information without a direct consumer relationship) or engages data brokers as vendors. Key clauses to examine include: (1) registration and annual fee payment obligations under the Delete Act; (2) procedures for handling consumer deletion requests, especially in anticipation of the 2026 DROP platform; (3) requirements to disclose collection of sensitive data (minors, reproductive health, precise geolocation) and report average response times; (4) mandates to include a CCPA rights link on relevant websites. Contracts may need amendments to explicitly allocate Delete Act compliance responsibilities, establish fee payment protocols, and integrate deletion request workflows that satisfy both current CCPA and future DROP requirements.

Contract Search Terms

data broker registrationannual fee paymentpenalty for non-registrationdeletion mechanism (DROP)consumer deletion requestssensitive data disclosureCCPA rights linkaverage response timedata broker registryannual reporting

Laws Cited

Violation Types

Entity Details

Entity

Data brokers

Also known as: Data Brokers

Industry

Data Broker

Official Sources

Related Enforcement Actions

CPPA

Data brokers (unspecified - advisory applies to all businesses registered with California's data broker registry)

CalPrivacy (the California Privacy Protection Agency) issued Enforcement Advisory 2026-01 warning data brokers that providing incorrect information in their annual registration with California's data broker registry carries liability of a $200 fine per day. The advisory observes that the Enforcement Division has already brought multiple enforcement actions over reporting errors, and emphasizes that accurate registry disclosures are what make the newly launched Delete Request and Opt-Out Platform (DROP) work for Californians. No specific company was named and no penalty was imposed by the advisory itself; it functions as forward-looking guidance.

CPPA

SalesIntel Research, Inc.

$36K

The California Privacy Protection Agency Board issued a Decision and Final Stipulated Order requiring Virginia-based data broker SalesIntel Research, Inc. to pay a $36,400 fine for operating as a data broker without registering by the 2025 deadline under the Delete Act. SalesIntel sells consumer personal information, including more than 200 million professional contacts and de-anonymized website traffic data, for targeted advertising. In addition to the fine, the company must post privacy rights metrics on its website, integrate with CalPrivacy's Delete Request and Opt-out Platform (DROP), and process future deletion requests through that system.

CPPA

Data brokers registered on California's DROP platform (654)

The California Privacy Protection Agency announced that more than 500,000 Californians have registered for the Delete Request and Opt-out Platform (DROP) since its January 1, 2026 launch. After the August 1, 2026 deadline for brokers to begin processing requests, 654 data brokers are in the system and approximately 25% have reported processing deletion requests, with tens of millions of records already deleted. No enforcement action has been announced yet; the agency warned that brokers who fail to delete eligible personal information face significant fines.

CPPA

Cybba, Inc.

$52K

The California Privacy Protection Agency Board issued an Order of Decision and Stipulated Final Order requiring Boston-based data broker Cybba, Inc. to pay a $52,400 fine for failing to register with the Agency's Data Broker Registry by the 2025 deadline, as required by the Delete Act. The order also requires Cybba to post metrics about privacy rights on its website, access the Agency's Delete Request and Opt-Out Platform (DROP), and process future deletion requests through that system. This is CalPrivacy's second data broker enforcement action announced in less than a week, following its action against LocateSmarter.

CPPA

LocateSmarter LLC

$116K

The California Privacy Protection Agency Board issued a decision and stipulated order requiring Iowa data broker LocateSmarter LLC to pay $116,490 and change its practices. The company failed to timely register as a data broker and unlawfully required Californians to provide the last four digits of their Social Security numbers before exercising opt-out rights, violating the CCPA's data minimization requirements. This is the first action against a data broker under both the CCPA and the Delete Act.

CPPA

California Privacy Protection Agency

The California Privacy Protection Agency announced that over 300,000 Californians have signed up for the Delete Request and Opt-out Platform (DROP) since its launch five months ago. The Data Broker Registry now includes 581 registered data brokers, the highest number since the registry was established in 2020. Beginning August 1, 2026, all data brokers will be required to access DROP and process deletion requests.