FPF Files Comments on Data Broker Registration Regulations to CPPA

FPF seeks to support balanced, informed public policy and equip regulators with the resources and tools needed to craft effective regulation. In response to the Agency’s public comment on data broker registration regulations, FPF recommends clarifying the definition of “direct relationship” to better align with user expectations on the forthcoming accessible deletion mechanism. Specifically, FPF encourages the Agency to consider:

• How the proposed definition may lead to unintentional data deletion requests, and
• Whether tying a “direct relationship” to recent user interactions may lead to the accessible deletion mechanism not operating as intended.