What is the average size of a bank’s California privacy notice?

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3,987 words (or 15 double spaced pages).

Banks and financial service companies (collectively “banks”) often post more than one privacy notice.  For example, they may post a privacy notice that applies to their customers and complies with the requirements of the Gramm-Leach-Bliley Act, and a second privacy notice that applies to non-customer California residents and complies (or attempts to comply) with the CCPA. The following shows the length of the privacy notices used by banks within the Fortune 500 to comply with the CCPA’s requirements:1

 

For more information and resources about the CCPA visit http://www.CCPA-info.com.


This article is part of a multi-part series published by BCLP to help companies understand and implement the General Data Protection Regulation, the California Consumer Privacy Act and other privacy statutes.  You can find more information on the CCPA in BCLP’s California Consumer Privacy Act Practical Guide, and more information about the GDPR in the American Bar Association’s The EU GDPR: Answers to the Most Frequently Asked Questions.

1. David Zetoony, February 2020: Survey of the Banking and Financial Service Privacy Representations.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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