Consumer Privacy, California Cannabis and CCPA Deletion Requests

The California Consumer Privacy Act (CCPA) took effect at the beginning of the year. CCPA is a massive privacy law similar in scope to the European Union’s infamous General Data Protection Regulation, and applies to many businesses (not just cannabis businesses) that are based in or even “do business” in California. I wrote about the thresholds for whether CCPA applies here, and the moral of the story is that the bar can be pretty low when it comes to application of the law.

For businesses that are subject to CCPA, compliance can be rough. One of the hallmarks of the law is that it provides California consumers with many new rights that they can exercise with respect to businesses that hold the consumers’ personal information. These rights include things like a right to direct a business not to sell consumer personal information, a right to know specifically what kinds of personal information a business collected, and importantly for this piece, a right to request that businesses delete personal information of the consumer.

The deletion right is what I want to focus on today. Per CCPA regulations, businesses that receive deletion requests must confirm receipt within a short period of

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