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US DPO: Data Subject Rights and Consent Management

US DPO · Work through your exam, one topic at a time.

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Data Subject Rights and Consent Management

What this domain tests

This domain tests the operational mechanics of consumer rights and consent: scope, verification, timelines, exceptions, authorized agents, appeals, and preference signals.

Core rules and concepts

  • Common rights in state laws: know/access, delete, correct, portability, opt out of sale/share, opt out of targeted advertising, limit sensitive data, and non-discrimination.
  • Timelines: CCPA/CPRA generally requires response within 45 calendar days, with a 45-day extension when reasonably necessary and notice given. Other states vary; some use 45 days, some 30 or 60.
  • Verification: match identity to data already held; do not collect extra sensitive data just to verify. Use authorized agents with written permission and appropriate verification.
  • Exceptions: legal obligations, security, free speech, internal use reasonably aligned with consumer expectations, and others vary by state.
  • Consent: opt-in for sensitive data where required, for sale of minors’ data under 16, and for certain marketing. Consent must be freely given, specific, informed, and unambiguous; dark patterns undermine it.
  • Preference signals: California requires businesses to honor Global Privacy Control as a valid opt-out of sale/share.

Worked example

A consumer emails a deletion request but the company’s records show two accounts-one consumer, one employee. The company verifies the consumer account, deletes eligible data, retains payroll records under a legal obligation, and explains the exception. It does not demand a passport copy.

Traps that cost marks

  • Applying a single 30-day GDPR deadline to all US requests.
  • Denying requests from authorized agents without checking state rules.
  • Treating “do not sell” as covering targeted advertising in every state; some have separate opt-outs.
  • Collecting more data during verification than the original record contained.