The Delete Act’s DROP system is not a delete-everything request sent to every California business. It is a centralized deletion process for registered data brokers—businesses that knowingly collect and sell consumers’ personal information to third parties when they have no direct relationship with those consumers. If your business only handles information from its own customers, the Act’s broker workflow may not apply to you. Start by checking your data practices, then use the steps below to identify and manage any broker-related responsibilities.
Does California’s Delete Act apply to your business?
California’s SB 362, the Delete Act, created the Delete Request and Opt-Out Platform, or DROP. The California Privacy Protection Agency adopted DROP regulations on September 26, 2025; the Office of Administrative Law approved and filed them on November 6, 2025, and they took effect January 1, 2026. See the CPPA’s regulation page.
The key question is not whether a company is small, or simply whether it holds personal information. The CPPA describes a data broker as a business that knowingly collects and sells personal information about consumers to third parties when it has no direct relationship with those consumers. Apply that definition to what your business actually collects, sells, and shares; do not assume that being small either brings you within the law or exempts you.
DROP is aimed at registered data brokers and broker-held information, including information held on a broker’s behalf by its service providers or contractors. It is not a universal request mechanism for deleting every record held by a business with a direct customer relationship. Other California privacy laws may create separate duties for businesses that collect information directly, but those are distinct from the Delete Act’s DROP process.
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10 practical privacy steps for small businesses
Steps 1–3 help any small business understand its data practices. The recurring DROP obligations in steps 4–9 apply when the business is a covered data broker; step 10 helps keep the assessment and response process accountable.
1. Map what information you collect and where it comes from
Make a working inventory of personal information, its source, where it is stored, and who receives it. Mark whether the person is your customer or otherwise has a direct relationship with your business. This gives you the facts needed to assess the broker definition instead of relying on a company label or a vendor’s description.
2. Separate your customer records from third-party data activity
Document first-party operations—such as processing a customer’s purchase—separately from any activity involving information about people with whom you have no direct relationship. Review whether your business knowingly collects and sells that latter information to third parties. A company may have different roles across different activities, so assess the activity rather than making a blanket assumption about the whole company.
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3. Review sharing arrangements and who acts on whose behalf
List the parties that receive personal information and the role each plays. Identify service providers and contractors that handle information for your business, and review relevant agreements and deletion procedures. For a covered broker, the DROP request concerns relevant broker-held information and can extend to information held by its service providers or contractors; the broker should plan for that reach rather than treating its own database as the entire response.
4. Decide whether broker registration duties apply—and calendar them
If your assessment indicates that you meet the data-broker definition, consult the current CPPA requirements on registration, accounts, and annual filing. The agency’s 2026 guidance lists a $6,000 annual registration fee plus an electronic-payment processing fee, and says the registration window runs January 1–31. These are 2026 details, not a promise that future fees or dates will remain unchanged. Check the state’s broker guidance and the California Data Broker Registry for current information.
5. Assign a named owner for DROP operations
A covered broker needs a person or team responsible for accessing DROP, coordinating matching and deletion, and reporting request status. Give that owner authority to work with data engineering, privacy, customer operations, and relevant service providers. A general privacy contact is useful for other businesses too, but it does not by itself make a company a data broker or satisfy broker-specific requirements.
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6. Build a recurring DROP access and intake schedule
Beginning August 1, 2026, covered brokers must access DROP at least once every 45 days, subject to limited exceptions described by the CPPA. Make access a recurring operational task with a backup owner and a record of completion, rather than relying on someone to remember it. Use current CPPA technical specifications and process guidance for the actual implementation.
7. Standardize records before matching them
The state’s broker workflow describes downloading consumer deletion lists, standardizing and hashing a broker’s own records, then matching requests to those records. Plan and test these steps against the current technical specifications so that formatting differences do not prevent a valid match. Avoid treating a high-level checklist as a substitute for the agency’s implementation details.
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Define what happens when a match is found: who initiates deletion, how relevant systems and service providers or contractors are notified, and how completion is confirmed. Document exceptions or operational failures for review rather than silently closing a request. The process should address information within the DROP scope, not indiscriminately delete every record your business holds about a direct customer.
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9. Report status within the required window
Covered brokers must report each request’s status in DROP within 45 days under the state’s broker guidance. Include status reporting in the workflow, assign an owner, and monitor unresolved requests so a deletion action is not mistaken for a completed response. California residents can submit one DROP request covering more than 600 registered brokers, according to the state’s current consumer guidance; that figure is the agency’s current page wording, not a permanent registry count.
10. Keep an auditable record and revisit the assessment
Keep appropriate records of the role assessment, registration decisions, DROP access, matching and deletion steps, status reporting, and issues escalated for resolution. Revisit the assessment when your data sources, sharing arrangements, or business model changes. This is a practical way to maintain accountability; it should not be mistaken for a claim that a particular software product or recordkeeping method guarantees compliance.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What does DROP mean for consumers and their requests?
A California resident can use DROP to send a deletion request to registered data brokers. The state says consumers must verify eligibility through the California Identity Gateway, but do not need to create a Gateway account; they can enter information directly or sign in through Login.gov. The service is free, and the state says information submitted to DROP is used to complete the request and is not retained by DROP. See the consumer instructions.
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The state says broker processing began August 1, 2026, and that status updates may take up to 90 days. That consumer-facing update period is different from the broker’s requirement to access DROP at least every 45 days and report request status within 45 days. The state notes that deletion may reduce targeted advertising or personalized content and could reduce some unwanted calls, texts, or emails, but results vary and can take time; DROP is not a guarantee against spam, scams, identity theft, or fraud.
What if a data broker ignores a DROP request?
California’s broker guidance lists penalties of $200 per day for failure to register and $200 per day, per deletion request, for each day a broker fails to delete information as required, in addition to investigation and administrative action costs. These are state-listed penalties tied to broker duties—not penalties that automatically apply to every small business that has customer data. A covered broker should use the CPPA’s current guidance for its obligations and response process.
