Multi-State Privacy Enforcement Sweep Highlights GPC Compliance Obligations

Nelson Mullins Riley & Scarborough LLP

On September 9, 2025, California Attorney General Rob Bonta, in coordination with the California Privacy Protection Agency and the Attorneys General of Colorado and Connecticut, announced a joint investigative sweep focused on businesses that fail to honor consumers’ opt-out requests submitted via Global Privacy Control (GPC) signals.

This announcement reinforces regulators’ continued focus on Global Privacy Control (GPC) compliance, building on California’s previous enforcement action—the $1.2 million settlement with Sephora for violations related to GPC signals. This coordinated action underscores the growing trend of multi-state privacy enforcement and heightened scrutiny of compliance with automated opt-out mechanisms under state privacy laws, including the California Consumer Privacy Act (CCPA), the Colorado Privacy Act (CPA), and the Connecticut Data Privacy Act (CTDPA).

  1. Recognize and honor GPC signals as valid opt-out requests. Have a clear understanding of what online tracking technology is deployed on the websites and what technologies are restricted via opt-out choices.
  2. Provide clear guidance regarding opt-outs and GPC signal rights.
  3. Where necessary, provide a clear and conspicuous “Do Not Sell or Share My Personal Information” link.
  4. Avoid requiring consumers to create an account to exercise opt-out rights.
  5. Establish a routine audit process or a website governance committee to ensure that websites comply with relevant regulatory frameworks, including via vendor diligence.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

© Nelson Mullins Riley & Scarborough LLP

Written by:

Nelson Mullins Riley & Scarborough LLP
Contact
more
less

PUBLISH YOUR CONTENT ON JD SUPRA NOW

  • Increased visibility
  • Actionable analytics
  • Ongoing guidance

Nelson Mullins Riley & Scarborough LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide