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Oregon (OCPA) Privacy Law Compliance

The Oregon Consumer Privacy Act (effective July 1, 2024) follows the Virginia template but adds a distinctive right — consumers can obtain a list of the specific third parties (not just categories) to whom the controller has disclosed personal data. Non-profits get an extra year (effective July 1, 2025) but no broad non-profit exemption like other states.

Statute
Oregon Consumer Privacy Act
Or. Rev. Stat. §646A.570 et seq.
Effective
Jul 1, 2024 (non-profits: Jul 1, 2025)
Enforcer
Oregon Attorney General
(exclusive)
Consumer rights
9
9 business obligations
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Who must comply

Exemptions

Consumer rights (9)

Right to access / know
Confirm whether personal data is processed and obtain a copy in a portable format
Right to correct
Correct inaccurate personal data
Right to delete
Request deletion of personal data the controller has collected
Right to data portability
Receive data in a portable, machine-readable format
Right to opt out of sale
Opt out of the sale of personal data to third parties
Right to opt out of targeted advertising
Opt out of cross-context behavioural advertising
Right to opt out of profiling with legal effect
Opt out of automated decisions producing legal or similarly significant effects
Right to appeal
Appeal a controller's refusal to honour a rights request (typically 45–60 days)
Right to know specific third parties
Receive a list of the SPECIFIC third parties (not just categories) to whom the controller has disclosed personal data

Business obligations (9)

Public privacy notice
Clear, accessible notice of categories collected, purposes, third parties, rights, and contact channel
Rights response within 45 days
Respond to consumer rights requests within 45 days (extendable by 45 more with notice)
Data processing agreements
Written contracts with processors restricting their processing to the controller's documented instructions
Data protection assessments
Document risk assessment for targeted advertising, sale, profiling, sensitive data processing
Honour universal opt-out signals (GPC)
Recognise the Global Privacy Control browser signal as a valid opt-out (where required)
Reasonable security practices
Administrative, technical, physical safeguards appropriate to the data's sensitivity
Data minimisation + purpose limitation
Collect only what is adequate, relevant, and reasonably necessary for the disclosed purposes
Children & teen consent
Opt-in consent before selling or sharing data of minors (age threshold varies 13–16)
Opt-in for sensitive data
Affirmative consent before processing sensitive data

Required privacy notice elements

  1. Categories of personal data processed (including, on request, the SPECIFIC third parties)
  2. Purpose of processing
  3. Active method to submit rights requests + appeal process
  4. Categories of personal data sold or processed for targeted advertising
  5. Opt-out instructions
  6. Statement of UOOM recognition
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Penalties

Civil penalty per violation
Up to $7,500
Or. Rev. Stat. §646A.604
30-day cure period
Sunset Jan 1, 2026
Cure now discretionary
Injunctive relief + restitution
Available
AG enforcement

Common compliance pitfalls

Inability to disclose specific third parties on request
Oregon's right to know SPECIFIC third parties (not just categories) is unique. Controllers must build the inventory + retrieval workflow — categorisation alone fails.
Assuming non-profit exemption
Most states fully exempt non-profits. Oregon does NOT — non-profits became subject to OCPA July 1, 2025. Non-profit healthcare, education adjacent organisations must comply.
Cure sunset
The 30-day cure window sunset January 1, 2026. AG may pursue penalties immediately.

FAQ

What's the specific-third-party right?
Oregon consumers can request not just categories of third parties (like every other state) but the specific names. Build a data-sharing inventory now; if you discover the request workflow on the day of the first request, you'll fail to respond within 45 days.
Does OCPA apply to non-profits?
Yes. Oregon is unusual in NOT broadly exempting non-profits — they became subject July 1, 2025 (one year after for-profits). Religious organisations are partially exempt.
Does Oregon honour GPC?
Yes, since July 1, 2024 effective date. UOOM honouring is built into OCPA from day one (unlike Colorado/Connecticut which phased it in).

Related state laws

California (CA)
CCPA/CPRA
Texas (TX)
TDPSA
Colorado (CO)
CPA

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