This morning, the California Privacy Protection Agency (“CPPA”) announced a $55,400 administrative fine on Washington-based data broker Accurate Append, Inc. for failing to register and pay an annual fee as required by the Delete Act.

The Delete Act applies to all “data brokers”, defined to include any 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. Data brokers are required to register with the CPPA on or before January 31 following each year in which a business meets the definition of a data broker.

As part of an ongoing investigative sweep of data broker registration compliance, the CPPA’s Enforcement Division found that Accurate Append failed to register by the January 31, 2024 deadline, despite having conducted business as a data broker during the 2023 calendar. Subsequently, the Enforcement Division contacted Accurate Append about its non-compliance, leading to its registration as a data broker.

Having already spent time and resources on the investigation, the CPPA was unwilling to overlook the delay. Accurate Append will now have to pay the CPPA $55,400 in fines, in addition to ensuring timely registration for any future years in which it operates as a data broker. If Accurate Append ceases operating as a data broker, it will need to inform the CPPA in writing before the deadline to register.

As the sixth enforcement action against an unregistered data broker in the past year, this is yet another indication that the CPPA is prepared to be aggressive in enforcing the Delete Act. In the words of CPPA’s head of enforcement, Michael Macko:

“[The CPPA is] committed to bringing transparency to the data broker industry, and vigorous enforcement of California’s registration requirement is one way to do that.”

You can read the Stipulated Final Order here.

As a reminder, the Delete Act has also tasked the CPPA with creating a “one-stop deletion mechanism” by January 1, 2026. All businesses meeting the definition of “data broker” will have to honor this mechanism starting August 1, 2026. For more information, check out: CALIFORNIA DELETE ACT: Less Than Six Months To Go Until Creation Of “One-Stop Shop” Deletion Mechanism For Data Brokers – CIPAWorld