Compliance Briefing — September 3, 2025
Two months into nonprofit enforcement, Oregon’s Consumer Privacy Act is testing consent processes, opt-out fulfillment, and sensitive data tagging at charities and foundations newly covered as of 1 July 2025.
Executive briefing: Oregon’s Consumer Privacy Act (OCPA) began applying to nonprofit organizations on July 1, 2025. Covered nonprofits must now honor access, deletion, correction, and portability requests within 45 days; recognize opt-outs of targeted advertising, sale, and high-risk profiling; and obtain consent before processing sensitive data such as precise geolocation, children’s data, or status as transgender or nonbinary. The Attorney General may bring actions with civil penalties up to $7,500 per violation after an available 30-day cure period.
Key compliance checkpoints
- Rights request routing. Stand up intake portals that authenticate donors, volunteers, and beneficiaries, and log decisions for 24 months as Section 646A.576 requires.
- Opt-out orchestration. Implement Global Privacy Control (GPC) handling and ensure marketing automation tools can suppress targeted advertising audiences within 15 days.
- Sensitive data governance. Tag and segregate sensitive categories, capturing explicit consent and storing consent records for audit review.
Operational priorities
- Processor alignment. Amend vendor contracts with confidentiality, duty-to-assist, and deletion clauses mirroring Section 646A.580.
- Appeals workflow. Document denial review procedures that deliver determinations within 45 days and provide Attorney General contact information to consumers.
- Cure readiness. Prepare remediation runbooks that can close identified violations within the 30-day cure window the Attorney General may offer.
Enablement moves
- Train development and communications teams on Oregon’s prohibition against dark patterns that obscure consent or opt-out choices.
- Refresh privacy notices to list categories of personal data processed, processing purposes, sharing practices, and rights instructions specific to Oregon residents.
Sources
- Oregon SB 619 (OCPA) enrolled text
- Oregon DOJ Consumer Privacy Act guidance
- IAPP coverage of Oregon’s privacy law
Zeph Tech equips nonprofits with OCPA compliance tooling, spanning consent capture, opt-out orchestration, and defensible consumer rights evidence.