Are You Sure You’re Not a Data Broker?
If you license, enrich, segment, or resell third‑party personal data, you should treat yourself as “potentially in scope” and do a documented applicability review, not rely on labels or industry norms.
The Evidence Question to Ask Yourself: Could you show a regulator a written analysis of why you are or are not a data broker in each applicable state?
CLIClaw’s Compliance Program Library includes data broker applicability tools you can adapt to your own structure.
