Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupportContact
Search
Close

California, Colorado, and Connecticut Launch Joint Privacy Sweep Over Opt-Out Rights

By A.J. Dhaliwal, Mehul Madia & Maxwell Earp-Thomas on September 18, 2025
Email this postTweet this postLike this postShare this post on LinkedIn
Privacy-Blog-Network-Security-660x283

On September 9, the California Privacy Protection Agency (CPPA) and the Attorneys General of California, Colorado, and Connecticut announced a joint enforcement sweep targeting businesses that may be failing to honor consumer opt-out requests under state privacy laws. The joint effort centers on the Global Privacy Control (GPC), a browser setting that automatically signals to companies that a consumer does not want their personal information sold or shared.

The sweep underscores increasing state-level enforcement of consumer privacy protections, particularly where businesses fail to recognize or process opt-out signals. Regulators emphasized that refusal to honor GPC requests could amount to violations of state privacy statutes, including laws modeled after the California Consumer Privacy Act. The announcement also follows earlier CPPA enforcement actions and highlights unfair, deceptive, or abusive practices (UDAP) concerns tied to ignoring consumer choices in online tracking and data sharing.

Specifically, the coalition’s announcement emphasized that businesses:

  • Must recognize GPC signals as opt-out requests. Companies are required to process GPC submissions as valid consumer opt-outs rather than forcing consumers to make site-by-site requests.
  • Cannot impose obstacles to opting out. State privacy laws require a clear “Do Not Sell or Share My Personal Information” link or equivalent mechanism, without conditioning compliance on account creation or other barriers.

Regulators are contacting suspected noncompliant businesses and directing them to come into compliance immediately, signaling that additional actions may follow.

Putting It Into Practice: The multistate sweep signals that honoring opt-out rights is an active enforcement priority for state privacy regulators, building on the CPPA’s recent rulemaking on ADMT, cybersecurity audits, and risk assessments (previously discussed here). Businesses should not only confirm their systems detect and process Global Privacy Control signals, but also review opt-out mechanisms for clarity and accessibility.

Photo of A.J. Dhaliwal A.J. Dhaliwal

A.J. is a partner in the Finance and Bankruptcy Practice Group in the firm’s Washington, D.C. office.

Read more about A.J. DhaliwalEmail
Photo of Mehul Madia Mehul Madia

Mehul Madia, special counsel in the firm’s Washington, D.C. office, provides deep consumer finance and fintech expertise to clients, leveraging more than 15 years’ of public and private sector experience.

Read more about Mehul MadiaEmail
Photo of Maxwell Earp-Thomas Maxwell Earp-Thomas

Max is an associate in the Finance & Bankruptcy Practice Group in the firm’s Orange County office.

Read more about Maxwell Earp-ThomasEmail
  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    Consumer Finance and Fintech Blog
  • Organization:
    Sheppard, Mullin, Richter & Hampton LLP
  • Article: View Original Source

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
The Library at LexBlog
  • About LexBlog
  • The Field We Built
  • Library at LexBlog
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo