If we do not think of ourselves as a data broker, do we still need to review the Delete Act?

Yes. The first step is to determine whether your actual data practices fit California’s definition of a data broker. Many businesses that sell, share, license, or aggregate consumer data may not use the label “broker” internally, but could still fall within the law.
Operationally, the safest approach is to:
  • Map what consumer data you collect, share, license, or sell;
  • Identify whether you receive or pass data through downstream partners;
  • Confirm whether you must register and use DROP; and
  • Document your analysis and build a repeatable compliance workflow if required.

 

Have a compliance question? Ask CLICBrain on CLIClaw.com – available 24/7.

 

For operational guidance and structured compliance documentation tools, visit the CLIClaw Data Broker Compliance Library.

 

This FAQ is provided for general informational purposes only and is not legal advice. It is intended as a starting point for understanding the issues discussed and should not be relied on as a substitute for advice from qualified legal counsel.