CPPA’s Tractor Supply Decision Offers Lessons As Enforcement Focus Moves From Education to Deterrence

The California Privacy Protection Agency (CPPA), in its recent landmark decision against national rural lifestyle retailer Tractor Supply Company, imposed the largest fine in the agency’s history and marked its first case addressing privacy notices and rights for job applicants. The action contains important compliance insights for all U.S. companies, not exclusively for those operating in California. This article discusses the implications of the Tractor Supply decision, including its signaling of the CPPA’s enforcement focus, guidance on responding to regulators and practical lessons for privacy compliance, featuring perspectives from enforcement specialists at Frankfurt Kurnit, IAB, Kelley Drye, Manatt, Phelps & Phillips, and Squire Patton Boggs. See “Cookie Compliance Lessons From the Todd Snyder Settlement” (Jun. 11, 2025).

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