As privacy laws evolve, companies are seeing a sharp rise in bulk consumer privacy requests—often submitted by third-party authorized agents. Managing these requests at scale can be overwhelming, especially when regulations vary by state and verification standards remain ambiguous. Here’s a closer look at what businesses need to consider, and how to build a scalable, compliant approach.
What Are Authorized Agents?
Authorized agents are third parties that act on behalf of individuals to submit privacy-related requests, such as accessing or deleting personal information. This concept gained traction with the emergence of laws like the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), which empower consumers to take more control over their data.
While this setup streamlines things for consumers, it introduces legal and operational challenges for businesses—especially when those requests come in bulk.
The Legal Patchwork Problem
There’s no one-size-fits-all approach to privacy compliance in the U.S.
- Some states, like California and Colorado, allow agents to submit deletion and access requests.
- Others don’t formally recognize third-party agents.
- And many still have no comprehensive consumer privacy laws at all.
This inconsistency puts businesses in a tough spot: Do you process all incoming requests the same way—or only those you’re legally required to?
The right approach often comes down to balancing compliance risk with brand trust. Businesses must decide where they stand on honouring requests beyond minimum requirements. Factors coming into play here are: organizations with large consumer facing surfaces attempting to build brand loyalty might not want to reject certain customers just because they are out of legal scope, and operational bandwidth – or the ability to respond to increased volume of requests from a systems and staffing perspective.
Getting Verification Right
At the heart of any privacy request is a core concern: Is this request legitimate?
To avoid releasing data to bad actors, companies need a clear verification process that works at scale. One best practice? Focus on email verification rather than requiring a government-issued ID, which may introduce unnecessary friction and risks.
The goal is to validate the consumer’s identity—and their relationship with the authorized agent—without making the process so cumbersome that it erodes trust and ends up collecting more personal information for verification purposes.
How to Handle Bulk Requests at Scale
If you’re managing a high volume of consumer requests, manual processes just won’t cut it.
Here are a few proven strategies:
- Automate where possible using consent management platforms (CMPs) or privacy request portals.
- Standardize intake forms so your team can triage and process requests efficiently.
- Define your internal policy for dealing with agent-submitted requests—even those outside of regulated states.
Operationalizing these practices ensures you’re not just reacting to privacy requests, but proactively managing them.
Looking Ahead: More Requests, More Complexity
Don’t expect this trend to slow down. With consumer awareness growing and state-level enforcement picking up steam, companies should expect:
- An increase in volume and complexity of privacy requests
- Greater scrutiny on verification procedures
- Rising demand for clear, consistent communication with consumers
Even without a federal privacy law on the horizon, the pressure to build trust through transparent data practices is here to stay.
Final Thoughts
Responding to bulk consumer privacy requests—especially through authorized agents—is no longer an edge case. It’s becoming a daily operational reality.
By investing in scalable systems, defining clear verification protocols, and staying ahead of legal developments, companies can navigate this evolving landscape with confidence—and earn consumer trust along the way.
Need more guidance? Book a consultation with our privacy experts today!
