Artifact GuideUSData Broker Registry and DROP

California Delete Act Data Broker Registry and DROP

Data Broker Registry and DROP decisions under the California Delete Act should be written in operational language: who is in scope, what must happen, what evidence proves it, and when escalation is needed.

This page offers practical steps for implementation planning. Confirm legal and policy assumptions before implementation.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

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

California's Data Broker Registry lists businesses that meet the state's definition of a data broker, and DROP is the state's Delete Request and Opt-Out Platform for handling deletion requests. This page explains what the registry and DROP are, who must register, what the annual registration and deletion workflow looks like, and which deadlines, evidence records, and review steps teams should track.

Section 1

What should teams decide about Data Broker Registry and DROP under the California Delete Act?

Start by confirming whether the business is a data broker under the Delete Act, meaning 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. If so, the business must register with the California Privacy Protection Agency and use DROP for the deletion workflow that lets consumers send one request to all registered data brokers.

Keep the statutory/regulatory source, threshold calculation, data category, consumer-right workflow, opt-out signal handling, and contract evidence together so California privacy decisions are reviewable.

  • Define the exact Data Broker Registry and DROP trigger and the business process it affects.
  • Record which role, product, system, customer group, or data flow is in scope.
  • Attach the source-linked rule, the owner, and the evidence field before approving the control.
  • Escalate uncertainty when the facts depend on thresholds, exemptions, cross-border activity, vulnerable users, or enforcement-sensitive wording.
Section 2

Who should own Data Broker Registry and DROP, and what evidence should prove the decision?

Ownership should sit with the team that can change notices, rights intake, consent/opt-out interfaces, data sharing, retention, vendor terms, or security evidence, with privacy counsel reviewing edge cases.

Evidence should show threshold calculations, privacy notice language, consumer request handling, GPC processing, sensitive-personal-information controls, service-provider/contractor terms, and risk/cyber/ADMT readiness where applicable.

  • Name one accountable owner and one reviewer for the Data Broker Registry and DROP workflow.
  • Keep source screenshots or source links, decision notes, implementation tickets, and approval records together.
  • Use dated evidence for deadlines, notices, risk assessments, contracts, user journeys, and regulator-facing records.
  • Review the evidence after product changes, new markets, new vendors, enforcement updates, or material changes in the source text.
Section 3

Which edge cases should teams check before relying on a Data Broker Registry and DROP decision?

Most CPRA mistakes happen at the boundary between CCPA and CPRA terminology, sale versus sharing, sensitive personal information, data-broker duties, and draft or phased regulatory requirements.

Review this section before launching a data flow, ad-tech integration, consumer interface, vendor contract, retention rule, risk assessment, or cyber audit control.

  • Check whether the rule changes for minors, consumers, business users, public-sector bodies, regulated sectors, high-risk services, or cross-border transfers.
  • Separate binding law, regulator guidance, consultation material, standards, and enforcement commentary in the evidence record.
  • Do not rely on a previous answer if the data categories, user interface, vendor role, or contractual flow changed.
  • Track unresolved assumptions in an open-questions section and route legal interpretation points for review.
Section 4

How should teams operationalize Data Broker Registry and DROP with proportionate controls?

Use a CPRA workflow that captures threshold status, data categories, consumer rights, opt-out signals, vendor role, retention logic, risk/cyber/ADMT trigger, owner, and review date.

The output should be a threshold memo, notice update, DSAR workflow, opt-out/GPC implementation record, vendor clause map, risk-assessment intake, or audit evidence pack.

  • Create a short intake question that identifies the Data Broker Registry and DROP scenario.
  • Map the answer to a required action, evidence field, owner, reviewer, and review date.
  • Review this flow to review scope, deadlines, controls, penalties, and templates before moving to the next implementation step.
  • Update the workflow when official source material changes or when internal evidence shows recurring exceptions.
Primary sources

References and citations

cppa.ca.gov
Referenced sections
  • CPPA registry source for confirming registered data brokers and the DROP registration step teams use before deletion processing.
"Data brokers must register and pay the annual fee between January 1-31, 2026, through the Delete Request and Opt-Out Platform (DROP)."
cppa.ca.gov
Referenced sections
  • Boundary and edge-case support for this artifact page.
"The CPRA amended the CCPA by adding additional consumer privacy rights and obligations for businesses"
cppa.ca.gov
Referenced sections
  • CPPA registry source for confirming registered data brokers and the DROP registration step teams use before deletion processing.
"Data brokers must register and pay the annual fee between January 1-31, 2026, through the Delete Request and Opt-Out Platform (DROP)."
cppa.ca.gov
Referenced sections
  • CPPA statutory compilation for the Data Broker Registry and Delete Act provisions effective January 1, 2026.
"DATA BROKER REGISTRY / DELETE ACT effective 01/01/2026"
cppa.ca.gov
Referenced sections
  • CPPA DROP regulations source for the accessible deletion mechanism and system requirements created under the Delete Act.
"requires the Agency to establish an accessible deletion mechanism"
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