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California Privacy Act Compliance and Data Broker Registration Requirement

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RichardNewman

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Oct 15, 2018
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California Governor Gavin Newsome has signed a number of proposals to amend the CCPA. One of them requires “data brokers” to register in a directory maintained by the California Attorney General.

The amendments are intended to replace or supplement the statutory text of the CCPA and were preceded by draft regulations released by the California Attorney General. The new regulations broadly cover seven topics, including, notices to consumers, how to handle consumer requests, how to verify the identity of consumers making requests, service provider restrictions, data metric compilation, minors’ personal information and non-discrimination.

The data broker that amends the CCPA is Assembly Bill 1202 and, while it is broader that its Vermont counterpart, it joins Vermont as the second state in the nation with such a law.

“Data Broker” Defined
“Data broker” is defined as “a business that knowingly collects and sells to third parties the personal information of a consumer with whom the business does not have a ‘direct relationship.’” The law defines “data broker” in a non-traditional sense and there is some debate about what constitutes a “direct relationship.”

Other definitions, including, but not limited to, “sale” and “personal information” are extremely broad and reference
 
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