To help identify trends in privacy representations, BCLP reviewed the websites and privacy notices of each pharmaceutical company listed within the Fortune 500.

The following summarizes current industry trends:

• Privacy notices are, on average, less than 2 months old, and have been updated more recently than other industries in the Fortune 500.
• The pharmaceutical industry universally updated their privacy notices for the CCPA; the rate of update far exceeded that found within most other industries.
• Unlike the Fortune 500 generally, pharmaceutical company privacy notices that reference enumerated categories are predominantly using lists (instead of tables or charts) to convey information.
• While a slight majority of companies state that they do not sell personal information, a significant percentage (nearly one in three) are silent or unclear about their selling practices which, itself, could be alleged to violate the CCPA.
• The vast majority of websites and privacy notices do not include a “Do Not Sell” option.
• Those companies that are disclosing the sale of information are complying with the CCPA’s requirement to provide a “Do Not Sell” option.
• Disclosure of access and deletion rights is universal.
• As an industry, pharma companies are not heavy users of behavioral advertising cookies.  Within the sector, however, there is significant divergence between companies.
• The average quantity of behavioral advertising cookies on a corporate homepage is 5.7.
• 31% of pharma companies are deploying a cookie notice or banner, and a significant portion of those are attempting to obtain opt-in consent.
• The deployment of a cookie notice only marginally correlates to the use of advertising cookies.

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