Relevant CCPA provisions (with links)
Under the CCPA section 1798.105):
- A consumer shall have the right to request that a business delete any personal information about the consumer which the business has collected from the consumer. ...
- A business that receives a verifiable consumer request from a consumer to delete the consumer’s personal information pursuant to subdivision (a) of this section shall delete the consumer’s personal information from its records and direct any service providers to delete the consumer’s personal information from their records.
- A business or a service provider shall not be required to comply with a consumer’s request to delete the consumer’s personal information if it is necessary for the business or service provider to maintain the consumer’s personal information in order to:
4. 1. Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer
4. 4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
4. 8.Comply with a legal obligation.
4. 9. Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Section 1798.140 (o) defines Pi as:
(1) “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:
(1) (A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
(1) (K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Later in 1798.140 subsection (t) (2) (A) provides that:
For purposes of this title, a business does not sell personal information when:
A consumer uses or directs the business to intentionally disclose personal information or uses the business to intentionally interact with a third party, provided the third party does not also sell the personal information, unless that disclosure would be consistent with the provisions of this title. An intentional interaction occurs when the consumer intends to interact with the third party, via one or more deliberate interactions. Hovering over, muting, pausing, or closing a given piece of content does not constitute a consumer’s intent to interact with a third party.
Under the CA AG's regulations implementing the CCPA A business must respond to a request to delete withing 45 days, which may be extend once for up to an additional 45 days. The business must indicate if it will comply, and if not, indicate the legal provision which permits or requires it to decline.
Communications sent from one user to another identifying the source user certainly fit the general definition of PI, as they are clearly associated with an identifiable person. However, under 1798.105 (4.1) a request may be declined to delete information which is needed to "provide a good or service requested by the consumer", or which is "reasonably anticipated within the context of a business’ ongoing business relationship with the consumer" may be declined.
It seems to me that in sending a message to another user of the service, a user clearly "requests" the service to provide this info to the other user. Moreover, this seems to be an action that is "reasonably anticipated. What is more, an argument could be made that the rights of the other user are impacted by any such deletion, although the CCPA, unlike the GDPR, does not require any balancing of the rights of others.
Thus I think a case can be made that a service provider such as Facebook need not delete messages sent by one user to another on a request by the sending user.
Beyond this, the CCPA does not grant any private right of action for requests to delete. That is the user is nor permitted to directly sue the business for such violations. Only the California Attorney General has the authority to bring such suits under the CCPA as it now stands.
I can find no reported litigation or enforcement action on the right to delete, much less on the right to delete in a fact pattern such as the question supposes. In the absence of any court decision or opinion by the CA AG, there is no way to be sure how the law should be interpreted.