Failure to register as data broker
Accurate Append, a Bellevue, Washington-based data broker, failed to register by the January 31, 2024 deadline covering its 2023 activities, and only registered after the Enforcement Division made contact during its investigation.
The action is notable for using Accurate Append’s marketing copy against it when establishing their qualification as a data broker: ‘Accurate Append conducts business as a data broker by knowingly collecting and selling to third parties the personal information of consumers with whom the business does not have a direct relationship. As Accurate Append explains it, “we live and breathe data.”’
The settlement includes an unusual injunctive term requiring the company to pay the Enforcement Division’s attorney fees and costs in the event of any future non-compliance, a stronger ongoing deterrent than a simple fine. The case reinforces that post-contact registration does not avoid enforcement consequences. Part of CPPA’s investigative sweep of data broker registration compliance, announced October 30, 2024.