At the California Privacy Protection Agency’s 2025 meeting, staff offered a first detailed look at the upcoming DROP system — the Delete Request & Opt-Out Platform mandated under the DELETE Act. It represents a major shift in how data brokers will handle consumer deletion and opt-out requests.
A One-Stop System for Data Deletion Requests
California’s new DELETE Act establishes a centralized state-run platform where consumers can submit a single deletion or opt-out request that applies to all registered data brokers. This platform, known as DROP (Delete Request & Opt-Out Platform), is designed to simplify consumer privacy actions and impose consistent technical obligations on data brokers statewide. For consumers, it promises convenience and transparency; for businesses, it brings new operational and compliance complexity.
How DROP Will Work
The DROP platform will operate through two connected interfaces — one for consumers and one for data brokers.
- Consumer portal: Individuals can create an account, verify their identity, and submit deletion or opt-out requests. Once verified, they will be assigned a unique DROP ID that can be used for ongoing updates or new identifiers (such as phone numbers, email addresses, or device IDs).
- Data broker portal: Registered data brokers will log in or connect via API to download or synchronize lists of hashed consumer identifiers to process and confirm deletion actions. Brokers must respond to requests within defined intervals and report completion status back to the agency.
The system will automatically synchronize requests every 45 days, ensuring that new data brokers and updates to consumer identifiers remain captured. For many organizations, this automation replaces manual, case-by-case deletion workflows with a continuous compliance obligation.
Who Must Comply
All entities classified as data brokers under California law must register with the California Privacy Protection Agency (CPPA) and integrate with the DROP system by January 31, 2026. To qualify as a data broker, an organization must collect, sell, or share personal information about consumers with whom it has no direct relationship. Each registered broker will pay an annual registration fee and must maintain updated contact details and compliance documentation. Failing to register could trigger daily penalties starting at $200 per day.
New Obligations for Data Brokers
- Implement secure authentication and access management for all staff handling DROP data.
- Hash all consumer identifiers before comparison to DROP request lists, ensuring no plaintext personal data leaves internal systems.
- Regularly check and act on incoming requests, deleting or suppressing relevant consumer records within the mandated timeframe.
- Maintain evidence of each deletion or suppression, including timestamped logs and confirmation records.
- Provide compliance certifications and respond to audit requests from CalPrivacy or the Attorney General’s Office.
- Protect backup and archival data through segregation and encryption to prevent accidental re-identification or re-exposure of deleted information.
Consumer Empowerment and Transparency
The goal of the DROP system is to make data deletion as simple and uniform as possible. Instead of requiring consumers to locate dozens of individual broker websites, the platform gives them a single point of entry. After identity verification, consumers can add multiple identifiers, track status, and see when data brokers confirm deletions. The state hopes this approach will reduce confusion and strengthen trust in California’s broader privacy framework.
Compliance Challenges for Businesses
For organizations, DROP introduces several operational hurdles. Brokers must integrate new API connections, manage regular file downloads, and ensure that their internal systems can match and delete data accurately. Failure to build reliable matching and deletion logic could create exposure to enforcement or consumer complaints. In addition, since deletion requests apply to all records — not just active databases — companies must review how they manage archives, backups, and historical datasets.
Key Risks of Non-Compliance
- Financial penalties: Daily fines for failing to register, plus enforcement actions for missed or incomplete deletions.
- Reputational harm: Data brokers that appear non-responsive to state deletion requests will be listed publicly, signaling poor compliance to clients and consumers.
- Audit exposure: The CPPA may audit registered brokers to confirm that deletion workflows, technical integrations, and logs align with statutory requirements.
How Privacy Teams Can Prepare
- Assess broker status: Determine whether your organization meets the definition of a data broker and, if so, initiate the registration process early.
- Update internal systems: Build automated routines to hash, match, and delete consumer identifiers from all repositories.
- Integrate with the API: Assign engineers to test the DROP sandbox environment and confirm data-exchange formats, encryption standards, and timing intervals.
- Train staff: Ensure privacy and IT teams understand how DROP requests differ from direct consumer deletion requests under the CCPA.
- Centralize compliance: Use a unified privacy management platform like the one we built here at CaptainCompliance.com to automate DSAR intake, deletion tracking, and broker integrations.
- Update privacy notices: Inform consumers and clients that your organization participates in DROP and honor deletion requests submitted through the state portal.
Why DROP Matters Beyond California
The DROP platform sets a precedent that could influence privacy infrastructure nationwide. Instead of relying solely on individual company portals, regulators are building official deletion ecosystems. This evolution shows that privacy enforcement is moving from reactive investigations to proactive technical systems where compliance is measurable, auditable, and automated. Other states — including Colorado, Connecticut, and Oregon — are watching closely as they consider similar centralized consumer-rights tools and thus the growing need for platform software like Captain Compliance.
The Bigger Picture: Privacy Infrastructure as Regulation
DROP represents a shift in how governments enforce data rights. By embedding consumer controls directly into state technology, California is creating a self-executing compliance layer. Data brokers will need to adapt not only to new legal standards but also to operational realities where regulatory technology interacts directly with their data systems. This marks the next stage in the evolution of privacy compliance: laws that come with APIs, not just paperwork.
Building Trust Through Deletion by Design
The California DROP system is more than another compliance requirement — it’s a blueprint for the future of data rights. Companies that embrace automated deletion, transparency, and real-time auditability will not only stay compliant but also strengthen consumer confidence in how they manage personal data. As enforcement begins in 2026, organizations should act now to integrate, document, and test their systems — because in the new world of data broker accountability, deletion is no longer a request; it’s an expectation.