CAADCA Section 1798.99.31(a)(3) - Data Retention Limits
Do not retain children's personal information longer than reasonably necessary for the actively used service; do not repurpose previously collected data without a compelling best-interests justification
Where this comes from
Provision: Section 1798.99.31(a)(3) - Data Retention Limits
Instrument: California Age-Appropriate Design Code Act (AB 2273)
Citation: Cal. Civ. Code § 1798.99.31(a)(3), California Age-Appropriate Design Code Act (AB 2273)
Text version: California Age-Appropriate Design Code Act, AB-2273 (2022); Cal. Civ. Code §§ 1798.99.28–1798.99.40
Who it applies to
It applies when all of these are true:
- Service is likely to be accessed by children under 18
- Service collects behavioral data
- Service processes personal data
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Each data category has a defined, documented retention period tied to a purpose
- Data past its retention period is automatically deleted or irreversibly anonymized (including backups)
- Retention periods for children's data are minimized and reviewed
- Deletion runs are logged (category, record count, timestamp) for audit
- A record past its retention window is removed by the scheduled job
Questions people ask
- Does CAADCA Section 1798.99.31(a)(3) - Data Retention Limits apply to my service?
- It applies when Service is likely to be accessed by children under 18; Service collects behavioral data; Service processes personal data.
- From when does this apply?
- CAADCA Section 1798.99.31(a)(3) - Data Retention Limits applies from 1 July 2024. Its current status is: in force.
Find out whether this one lands on you
Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.
Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.