Did California pull a fast one on us? Because the expanded data broker definition was supposed to be live in April…and it’s live now.
Alysa Hutnik and Jonathan Joseph are kicking off the Privacy Huddle in 2025 with an important, messy (it’s ok you two–it’s not your fault) discussion on how the CPPA is defining a data broker.
Possible brand scenarios:
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You have very little first party data, and you purchase third party data to run an advertising campaign. Does that make you a data broker?
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You have plenty of first party data, and you purchase information about just one audience attribute to append to your data set for advertising. Does that make you a data broker?
Being defined as a data broker has implications for customer perception of your brand AND increased scrutiny from regulators. This is a must watch for brand privacy and marketing leaders. 👀




