No.
The CCPA requires that a business that collects a consumer’s personal information provide the consumer “at or before the point of collection” certain information regarding what will be collected, the purpose of the collection, the business’s sale practices, and where the consumer can find the business’s privacy notice.1
The regulations implementing the CCPA clarify that the requirement to provide a “notice at collection” only applies, however, when a business collects personal information “from the consumer.”2 In situations in which a business collects personal information about a consumer, but collects the personal information from a third party, the regulations implementing the CCPA make clear that the business “does not need to provide a notice at collection” so long as the business does not intend to sell the personal information.3 If the business intends to sell the personal information, a notice at collection is still not required if the business complies with California’s rules regulating data brokers.4
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. CCPA Section 1798.100(b); CCPA Reg. Section 999.305(b)(1)-(4).
2. CCPA Reg. Sections 999.301(l); 999.304(b).
3. CCPA Reg. Section 305(d) (emphasis added).
4. CCPA Reg. Section 305(e). See also Cal. Civil Code 1798.99.80 et seq (regulating data brokers).
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