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The CCPA Regulations require that businesses that buy, receive, sell, or share personal information about more than 10 million Californians disclose metrics within their privacy notices regarding the speed with which they respond to the data subject requests that they received in the previous calendar year. Among other things, businesses must report the average or median number of days that elapse before they respond to deletion requests.[1]

Based upon a review of the websites of the Fortune 500, major retailers spent an average of 26 days to respond to the deletion requests that they received.[2] It is important to note, however, that there was a wide dispersion within the industry in the amount of time that was needed to respond to deletion requests. Specifically, some companies responded in as little as seven days whereas other companies responded in 52 days. It is also worth noting that many companies did not clearly indicate whether they reported based upon their average or median response times, thereby making an apples to apples comparison of this metric challenging.

1 Cal. Code Regs. tit. 11, § 999.317(g) (2021).

2 Review was conducted in August of 2021.