The 45-Day Deletion Cycle: A Complete SOP for DROP Portal Compliance
Why You Need a Formal SOP
The 45-day deletion cycle is not something you can handle ad hoc. It requires coordinated action across multiple teams (compliance, IT, marketing, legal), strict deadlines at each stage, and thorough documentation. A formal Standard Operating Procedure ensures that nothing falls through the cracks, that responsibilities are clearly assigned, and that your business can demonstrate compliance in the event of a CPPA audit. Without an SOP, even well-intentioned businesses will miss steps, blow deadlines, and accumulate fines.
Week 1: Retrieval and Matching (Days 1-7)
The cycle begins when your compliance officer logs into the DROP portal and downloads the latest batch of consumer deletion and opt-out requests. The CSV export is immediately imported into your tracking system and run against your data map to identify which requests match records in your systems. Each request is categorized as Match (consumer data found and must be deleted), No Match (no records found), or Exempt (a documented legal exemption applies). By end of week one, every request should be categorized and assigned to the responsible team for action.
Week 2: Internal Deletion (Days 8-14)
For each matched request, the responsible system administrator deletes or anonymizes the consumer's personal information from every system identified in the data map. This includes CRM platforms, email marketing tools, analytics databases, file storage systems, and any other repository. Each deletion is logged in the compliance tracker with the date, time, system, and person who performed it. Backup systems are flagged for exclusion to prevent the data from being restored in future backup operations.
Week 3: Downstream Notification (Days 15-21)
Within two business days of completing internal deletions, the compliance officer sends downstream deletion notices to every vendor, service provider, or third-party partner that received the consumer's data. The notice includes the request details and a deadline (typically 15 business days) for the vendor to confirm deletion from their own systems. Vendor responses are tracked in the compliance log. Non-responsive vendors receive a follow-up notice and, if necessary, are escalated to legal counsel.
Weeks 4-5: Verification (Days 22-35)
During the verification phase, the compliance team confirms that all internal deletions were completed successfully through spot-checks and system queries. Vendor deletion confirmations are collected and logged. Any outstanding items are escalated to the appropriate team lead. The compliance report is run to verify that all requests have a documented final status. This is also the time to identify and resolve any edge cases, such as data that falls under an exemption or records that exist in systems not covered by the original data map.
Week 6: Reporting and Close (Days 36-45)
In the final phase, the compliance officer logs back into the DROP portal and updates the status of every request. Each request is marked as Completed, Not Found, or Exempt with supporting documentation. The cycle's records are archived including the original DROP CSV, match reports, deletion logs, vendor communications, and the compliance report. The annual reporting tracker is updated with this cycle's metrics. Finally, the team prepares for the next cycle, which begins immediately.
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