California’s Delete Act (SB 362) will change how consumer data gets erased. By Jan. 1, 2026, the California Privacy Protection Agency (CPPA) must launch a one-stop portal where individuals can submit a single deletion request that applies to all registered data brokers.
If your marketing utilizes third-party data — such as lead lists, enrichment, or identity graphs — this affects you.
Here’s the short list to get ready:
- Map your data brokers. Maintain a live inventory of all vendors that buy, sell, or license personal data used in your campaigns. Many operate behind the scenes (list compilers, append services, verification APIs). Require written confirmation that they’re CPPA-registered and track their registration IDs.
- Fix your deletion playbook. Today, you route CCPA delete requests to each vendor. In 2026, requests will also arrive through the CPPA’s portal (DROP). Assign an owner, set SLAs, and document how deletes propagate to your CRM, CDP, ad platforms, and warehouses — without “dark pattern” friction.
- Update your notices. Refresh your privacy policy and in-product notices to include the categories of data you share with brokers and to link to the CPPA portal once it becomes available. If you operate as a data broker yourself, your obligations (including registration, reporting, and security) are stricter.
- Audit your vendors. The CPPA approved new CCPA rules on risk assessments and automated decision-making in July 2025 (pending final state review). If you use scoring or audience models, expect questions. Add termination rights if a vendor misses deadlines, refuses to delete, or hides opt-out pages from search.
- Train your front lines. Teams that run forms, events, and email must verify identities, honor unsubscribes, and recognize deletion rights. Build simple macros: confirm requests, verify identities, and confirm completion.
Bottom line for San Diego: Hospitality, higher education, and nonprofits rely heavily on third-party data. Do the prep now and you’ll avoid last-minute scrambles — and earn trust when residents ask for their data to be deleted.
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