Can a service provider refuse a deletion request that it receives directly from a consumer under the CCPA?

Yes.

A consumer may incorrectly direct a deletion request to a service provider rather than to the business for which the service provider processes personal information.  Service providers are permitted to refuse deletion requests that they receive directly from a consumer, as the CCPA  only allows consumers to request deletion from a business.¹ 

For more information and resources about the CCPA visit http://www.CCPA-info.com. 

This article is part of a multi-part series published by BCLP to help companies understand and implement the General Data Protection Regulation, the California Consumer Privacy Act and other privacy statutes.  You can find more information on the CCPA in BCLP’s California Consumer Privacy Act Practical Guide, and more information about the GDPR in the American Bar Association’s The EU GDPR: Answers to the Most Frequently Asked Questions.

1. CCPA § 1798.105(a)

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