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Artifact GuideUSData Broker Crossover

US CCPA Data Broker Crossover

A CCPA business may also be a California data broker when it knowingly collects and sells personal information about consumers with whom it lacks a direct relationship, creating separate registration and DROP duties.

Use the focused answer for the immediate question, then preserve the applicable source, facts, owner, action, deadline, evidence, and reassessment trigger in the related CCPA workflow.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Questions
3

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

A CCPA business is also a California when it knowingly collects and sells to third parties personal information about a consumer with whom it has no direct relationship, unless a statutory exclusion applies. Data brokers keep their ordinary CCPA duties and also face annual registration, public metrics, and Delete Request and Opt-out Platform () duties.

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3 of 3 questions
Question 1

What should teams do about Data Broker Crossover under the US CCPA?

Apply the definition to the entity, not to a product label. Confirm that the entity is a CCPA business, knowingly collects personal information, sells that information to third parties, and lacks a direct relationship with the affected consumers. Then check the statute's exclusions, including specified consumer-reporting, financial, insurance, and health-data activities.

A direct relationship exists when the consumer intentionally interacts with the business, but the exact facts matter. Buying data indirectly, collecting it from public sources, or operating a consumer-facing site does not by itself resolve whether the business has a direct relationship with each affected consumer.

  • Register with CalPrivacy between January 1 and January 31 after each year in which the entity met the data-broker definition.
  • Publish the required prior-year request metrics by July 1 and report them during annual registration.
  • Beginning August 1, 2026, access at least once every 45 days and process each matched deletion or fallback opt-out request within 45 days after receiving it through the platform, subject to statutory exceptions. The two periods can result in up to 90 days from the consumer's submission.
  • Direct associated service providers and contractors to delete covered information or process the required opt-out.
  • Prepare for independent audits beginning January 1, 2028 and every three years thereafter; keep the audit report and related materials for at least six years.
Citations
Question 2

What evidence should teams keep for Data Broker Crossover under the US CCPA?

Keep separate evidence for the data-broker classification and for each recurring duty. A registration receipt does not show that requests, vendor instructions, or ordinary CCPA requests were handled.

  • Entity-level definition analysis, direct-relationship evidence, sale mapping, and any relied-on exclusion.
  • Annual registration submission, fee record, public registry entry, and the website privacy page containing required disclosures and metrics.
  • access logs, match results, deletion decisions, statutory exception codes, completion dates, and directions sent to service providers or contractors.
  • Independent audit reports from 2028 onward and proof that reports and related materials are retained for at least six years.
Citations
Question 3

Which mistakes create risk when handling Data Broker Crossover under the US CCPA?

Do not collapse the two regimes into one generic privacy workflow. The CCPA and Delete Act use related concepts but impose different submissions, dates, system interactions, and records.

  • Assuming that registration satisfies the business's CCPA notice, access, deletion, correction, opt-out, or limit duties.
  • Treating every indirect-data business as a without testing the statutory definition and exclusions.
  • Missing the January registration window, July metrics disclosure, 45-day access cycle, or 2028 audit schedule.
  • Deleting only the broker's copy while failing to direct service providers and contractors as the Delete Act requires.
  • Deleting information covered by an exception without recording the legal basis, or using an exception more broadly than the statute allows.
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Recommended next step

Turn US CCPA Data Broker Crossover into assigned work

Keep the data-broker classification, registration, metrics, DROP processing, vendor directions, and audit record under named owners.

Assessment workflow
Open Assessment Autopilot for US CCPA

Turn Data Broker Crossover into scoped questions, evidence fields, and review tasks.

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Review US CCPA source evidence

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Primary sources

References and citations

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