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Warning LetterLow Risk

NJ Division of Consumer Affairs Warns Auto Dealerships on Data Deletion Law

auto dealershipsJuly 28, 2025New Jersey Attorney General

Summary

The New Jersey Division of Consumer Affairs sent warning letters to over 3,000 auto dealerships reminding them of the state's data deletion law, which requires dealerships to offer to delete personal data from vehicles when accepting them for resale or lease. Failure to comply can result in fines of $500 for first offenses and $1,000 for subsequent offenses, aimed at preventing unauthorized access to sensitive consumer information stored in vehicle infotainment systems.

Remedy

Dealerships must offer to delete consumers' personal data from vehicles by following manufacturer-specified techniques or performing a factory reset. They are permitted to charge a reasonable fee for this service but must disclose it in advance, and must also advise consumers that they may delete the data themselves or through another vendor.

Corrective NoticeData Deletion

Contract Impact

In-house legal teams should review customer sales and lease agreements (especially trade-in or buyback terms), vendor service agreements (e.g., with detailing or tech service providers), and any data processing agreements involving vehicle data. Key clauses to examine include data deletion obligations, data retention schedules, consent mechanisms for personal data processing, and breach notification provisions related to infotainment systems. Changes may be needed to explicitly require offering data deletion services upon vehicle acceptance for resale or lease, define standardized procedures for wiping infotainment systems, update privacy notices to reflect deletion rights under New Jersey law, and incorporate compliance warranties or indemnities to mitigate fines of $500-$1,000 per violation.

Contract Search Terms

data deletion offervehicle data erasureinfotainment system clearanceresale data removal requirementlease return data deletionconsumer data deletion rightdata retention policy for vehiclesbreach notification for vehicle dataprivacy policy for connected carsdata sanitization clause

Laws Cited

New Jersey data deletion law

Violation Types

Entity Details

Entity

auto dealerships

Also known as: Auto Dealerships

Industry

Automotive

Official Sources

Source Evidence

Entity Name
"auto dealerships statewide"
Laws Cited
"the New Jersey data deletion law"
Violation Types
"mandates that dealerships offer to delete consumers’ personal data when accepting vehicles for resale or lease."

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