What are the SB 923 disclosure requirements for Mighty Media LLC?

Understanding SB 923 Disclosure Obligations

Mighty Media LLC must comply with California’s SB 923 by providing clear and accessible disclosures regarding its collection and use of personal information. The company is required to update its privacy policy to explicitly outline the categories of personal data gathered, the purposes for which this data is utilized, and the specific third parties with whom such information is shared. This transparency ensures that consumers are fully informed about how their sensitive details are handled within the publishing network’s operations.

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Additionally, the disclosure must detail the retention period for collected data and explain the consumer’s rights to access, correct, or delete their personal information. Mighty Media LLC must also inform users about the methods available for exercising these rights, ensuring that the process is straightforward and accessible. Failure to provide these comprehensive disclosures could result in significant legal consequences, including regulatory penalties. By adhering to these requirements, the company not only fulfills its legal obligations but also builds trust with its audience through greater transparency and accountability in data handling practices. This proactive approach aligns with the broader goals of California’s privacy legislation, which aims to empower consumers with greater control over their personal information.

Impact on Mighty Media LLC Operations

For Mighty Media LLC, the company behind mightymediallc.com and its publishing network, SB 923 would expand the disclosure obligations already in place under the CCPA and CPRA. If the company meets California's business thresholds, its privacy policy would need to clearly list the categories of personal information collected from California consumers, the sources of that data, and the specific business or commercial purposes for each category. For a digital publisher that relies heavily on advertising technology, this would mean moving away from vague references to "third parties" and instead disclosing the categories of recipients, particularly when personal information is shared for cross-context behavioral advertising.

These heightened duties would not be limited to the privacy policy alone. SB 923 would also require Mighty Media LLC to provide a more detailed notice at collection on its website, one that accurately reflects its actual data flows rather than generic cookie language. With California regulators placing greater emphasis on truthful, specific disclosures, any mismatch between the notice at collection and the privacy policy could draw scrutiny. As a result, the company would need to review its ad partners, tracking tools, and existing policy language to ensure full compliance with these new transparency requirements.

Compliance Steps for Publishing Networks

SB 923, enacted as part of California's end-of-session privacy package, imposes new disclosure obligations on businesses that collect and share personal information with third parties, and Mighty Media LLC must assess how these requirements apply across mightymediallc.com and its network of publishing properties. The law requires covered entities to clearly disclose the categories of personal information they collect, the purposes for that collection, and the third parties with whom data is shared, particularly where such sharing may enable targeted advertising or data brokers. Because a publishing network typically relies on ad tech, analytics providers, and audience measurement tools, Mighty Media LLC should inventory every data flow across its sites and confirm that its privacy policy accurately reflects each one. The firm's obligations are heightened where sensitive categories of data are involved, and disclosures must be conspicuous rather than buried in lengthy terms of service.

Mighty Media LLC should also monitor the effective dates and implementing guidance, since several of the bills in California's 2026 legislative package take effect on staggered timelines and await regulatory clarification. Legal commentary from firms including Freshfields, Kelley Drye, Nixon Peabody, Holland & Knight, and WilmerHale suggests businesses should begin compliance mapping now rather than waiting for enforcement. Updating privacy policies, vendor contracts, and consent flows across the network will position Mighty Media LLC to meet SB 923's disclosure standards as they come into force.

Consumer Rights Under New Legislation

For Mighty Media LLC, the SB 923 disclosure requirements center on transparency about how consumer personal information is used in connection with automated decision-making and profiling. The law obliges businesses like Mighty Media to inform consumers, at or before the point of collection, whether their data will feed into automated systems that make significant decisions, and to explain the logic and likely outcomes of those processes in plain language. Mighty Media must also disclose the categories of information used, the sources of that data, and any third parties receiving it.

Beyond the initial notice, SB 923 requires Mighty Media to provide accessible mechanisms for consumers to request additional details about automated decision-making and to opt out where the practice produces legal or similarly significant effects. The company must honor these requests without discrimination and maintain records demonstrating compliance. Because the law is part of California’s broader end-of-session privacy package, Mighty Media should align its privacy policy, consent flows, and vendor contracts with these disclosure duties to avoid enforcement exposure.

Future Privacy Regulation Trends in CA

California's SB 923, enacted as part of the end-of-session privacy package, establishes new disclosure obligations for direct-to-consumer genetic testing companies, not for general publishing businesses like Mighty Media LLC. Under the law, genetic testing companies must provide clear disclosures about how biological samples and genetic data will be collected, used, retained, shared, and destroyed, and they must obtain separate consumer consent before sharing genetic data with third parties. Because Mighty Media LLC operates mightymediallc.com as a publishing network, it would fall within SB 923's scope only if it were itself offering genetic testing services or handling genetic data in that capacity, which a content publisher typically does not do.

That said, SB 923 is relevant to Mighty Media LLC in its capacity as a source of published commentary. As law firm analyses from Freshfields, Kelley Drye, Nixon Peabody, Holland & Knight, and WilmerHale emphasize, companies should monitor how California's expanding privacy and AI statutes reach adjacent sectors, since disclosure and consent expectations continue to broaden across consumer-facing businesses.

SB 923 Compliance Comparison

Mighty Media LLC should map personal data across its publishing network, then update every notice at collection and privacy policy to state categories, purposes, recipients, retention, and California rights. It should add clear opt-out and limit-use links, honor opt-out preference signals, document vendor contracts, and train staff. If SB 923 is not yet effective, treat these steps as compliance best practice and monitor final text.