Beginning on 1 January 2028, the mandatory audit obligations in Civil Code Section 1798.99.86(e), as enacted by Senate Bill 362 (DELETE ACT), are required to be implemented by data brokers. These obligations require each data broker to undergo an audit by an independent third party to determine compliance with the deletion-mechanism provisions, with the audit requirement recurring every three years thereafter. For each audit, the data broker must submit the audit report and any related materials to the California Privacy Protection Agency within five business days of a written request issued by the agency, and must retain the audit report and materials for at least six years.
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