“Delete me” apps
Because the CCPA allows consumers to designate “authorized agents” to access and delete information on their behalf, app builders will create apps that allow consumers to authorize the app to submit deletion requests on their behalf to hundreds of retail stores, websites, online operators, social media platforms, and other institutions with a single “submit” button.
This will create a cottage industry for app developers and will be burdensome for businesses to respond to, because many consumers may not even have an account with the retailer or website. And yet, the CCPA will require the business to confirm receipt of the request, look for responsive data, and ultimately deny the request because there is no data to delete.