What you need to know about California’s new Consumer Privacy Act

by Dickenson Peatman & Fogarty P.C.
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[co-author: Louise Mercier, Junior Associate]

If you recently updated your company’s privacy policies in response to the European Union (“EU”) General Data Privacy Regulation (“GDPR”) in the United States – or, decided you did not have to – you may be suffering from some whiplash in light of the recently approved California Consumer Privacy Act.

On June 28, 2018, Governor Brown signed into law the California Consumer Privacy Act of 2018 (“CCPA”) (AB 375) codified in California Civil Code (“Cal. Civ. C.”) Part 4 of Division 3, relating to privacy.  The GDPR reinforced E.U.’s users’ privacy rights, and the CCPA pursues similar goals.

State Senator Bill Dodd (D-Napa), co-sponsor of the bill, says CCPA puts California once again in “the lead in protecting consumers and holding bad actors accountable. My hope is other states will follow, ensuring privacy and safeguarding personal information in a way the federal government has so far been unwilling to do.”

Sen. Dodd added that “[a] lot of time and effort was put into the original bills and the initiative. This is a great example of people working together and getting something done for consumers.”

Before you start rewriting your privacy policies and terms and conditions of use, there are two important caveats.  First, the law will not go into effect until January 1, 2020, so you have significant lead time if you need to come into compliance.  Second, CCPA only applies to those engaged in business in California that either: (a) have annual gross revenues of $25 million or more; (b) buy, receive, sell, or share the personal information of 50,000 or more consumers (defined in the CCPA as California residents), households or devices on an annual basis; or (c) have 50% or more of its annual revenues coming from the sale of personal information of California residents. Cal. Civ. C. §1798.140(c)(1)(a), (b) and (c).  Note, however, that you may already be covered by existing California data privacy laws that do not contain these limitations.

The CCPA also includes a comment period that may result in changes to the law before it goes into effect, so it is possible that there will be additional changes to the requirements discussed below.  If you believe you will be adversely affected by the law, you may be able to comment on those provisions.  But, as of now, the thresholds to be covered are set so if you are a small business with less than $25 million in revenue, not annually dealing in 50,000 consumers’ data, or not in the business of selling personal information, you are not covered by the CCPA.

The CCPA brings many of the concepts in the GDPR to California.  But, the two are not entirely overlapping or harmonious.  The CCPA shows more concern over the sale of consumers’ information, but does not address data processing in the extensive way that the GDPR does.  Since there has been much discussion of the obligations under the EU’s GDPR already (see our earlier post here), this post summarizes some of the key similarities and differences between the two regulations.

Similarities Between GDRP and CCPA

Among the most noticeable similarities, the two regulations provide consumers with the right to obtain disclosure of the personal information a company has, as well as disclosure of the source of collection, the nature of the information collected, whether the information was disclosed, transferred or sold to third parties and the business purpose justifying the storage of data. Cal. Civ. C. §1798.110(a)(1) through (5); GDPR Art. 14 Sec.1 (b) through (c) and Art. 13 Sec.1(c).  The GDPR further provides that a business must disclose the period during which the information is stored. GDPR Art. 13 Sec. 2(a).

Under the GDPR, a user may require at any time and without limitation, disclosure of the personal information held by a company. GDPR Art. 15.  The CCPA provides for a similar system, but companies are only required to respond to two requests from any individual consumer in any twelve month period. Cal. Civ. C. §1798.100(d). The CCPA also requires the business to provide the information free of charge, within 45 days of the request. Cal. Civ. C. §1798.130(a)(2).

Both the GDPR and the CCPA provide users with a right of deletion of their personal information. Both also set forth exceptions that enable a company to deny a deletion request. But the CCPA provides more exceptions than the GDPR does. First, both allow a business to refuse to delete someone’s personal information for certain legitimate interests such as third party safety and protection, to satisfy legal requirements, protect third parties’ interests and rights, to guarantee individuals’ freedom of speech and expression and allow use of information for scientific, historical, and statistical research in the public interest. Cal. Civ. C §1798.105 (d)(1) through (9); GDPR Art. 17 Sec. 3(a) through (e). The CCPA, as the GDPR, Art. 17 Sec. 1(a), additionally allows a business to deny a disclosure request if the information held by the company is necessary to complete a transaction for which the information was collected or reasonably expected by the business in the course of its relationship with the consumer (Cal. Civ. C. §1798.105(d)(1)), or if the information is necessary to identify, debug, and repair errors that impair existing intended functionality (id at (3)).

Both regulations provide users with a right to opt-out if a business sells personal information about the consumer to third parties. Cal. Civ. C. §1798.120(a); GDPR Art. 21.  The CCPA further authorizes a business, every 12 months, to contact individuals who previously opted out to obtain their consent to sell their information. Cal. Civ. C. §1798.135(a)(2)(B)(5).

Both regulations require businesses to inform a user of the consequences of refusing to disclose his personal information. The CCPA however, specifically prohibits a business from discriminating against a user who refused to provide his personal information or otherwise exercise its rights under CCPA, and the law gives a detailed list of prohibited discriminatory practices. Cal. Civ. C. §1798.125(a)(1)(A) through (D). Among those practices, a business may not refuse to sell goods or services to a consumer, charge different prices or rates, or provide a different level or quality of goods or services to the consumer.

Both regulations also require a business to collect information for proper purposes. The GDPR requires it be “collected for specified, explicit and legitimate purposes” as well as “adequate, relevant and limited to what is necessary.”  GDPR Art. 5 Sec. 1(b) and (c).  Similarly, the CCPA requires collection by a business be “reasonably necessary and proportionate to achieve its operational business purpose.” The CCPA adds that if a business wishes to collect more than what is strictly relevant to its operational purpose, notice to the data subject must be provided. Cal. Civ. C. §1798.100(b).

The CCPA, as the GDPR, sets special restrictions regarding the use of information from individuals aged 13 to 16. The CCPA prohibits a business in actual knowledge that a consumer is under 16 years of age from selling the individual’s information, unless the child, between 13 and 16 years old, personally consents to the sale, or the child’s parents consent on behalf of a child under 13 years old. Cal. Civ. C. §1798.120(d).  The GDPR’s Article 8 precludes the use of such information at all without parental consent, when consent is required for use of the data.

Lastly, the GDPR and the CCPA both create private causes of action for data subjects. However, enforcement mechanisms are distinct. The GDPR creates local “supervisory authorities” where private individuals can file complaints against an entity’s use of their data. It also has a private right of action for damages.  The CCPA similarly creates a private cause of action for data subjects, Cal. Civ. C. §1798.150(b)(1), and provides for enforcement of its provisions by the California Attorney General. Cal. Civ. C.  §1798.150(b)(1)(A).

It should also be noted that previous California laws already covered some of the concepts included in the GDPR. And those provisions are not limited to the $25 million revenue cap or other limitations on the applicability of the CCPA.  Prior laws include the obligation to provide reasonable security of personal information (Cal. Civ. C. §1798.81.5), notification of data breaches (Cal. Civ. C. §1798.82), and disclosure of data sharing for marketing purposes (Cal. Civ. C. §1798.83). (Compare with GDPR Arts. 32, 34, and 13 respectively).  Thus, the CCPA adds to an already existing California data privacy regime; it does not replace it.

The Differences

Obviously, the main difference between the GDPR and the CCPA is their respective applicability. The GDPR applies to E.U. residents’ personal information whereas the CCPA applies to personal information of California residents.  But the biggest conceptual difference is the GDPR’s focus on data processing.  The GDPR contains far more requirements for data processors, including specific dictates on data protection.  It is concerned both with the accuracy of data and its security; and the risk that inaccuracy or misappropriation may negatively impact persons’ fundamental rights.

The CCPA too attests a goal to prevent the misuse of consumer’s data, specifically referencing the Cambridge Analytica data mining situation in its findings.  AB 375, Sec. 2(g).  It reemphasizes the “duty to implement and maintain reasonable security procedures and practices appropriate to the nature of the information to protect the personal information” in its private cause of action. Cal. Civ. C. §1798.150(a)(1).  That duty comes from preexisting California law.  Cal. Civ. C. §1798.81.5.

However the CCPA spends more time addressing the purchase and sale of consumers’ data, and the business aspects of dealing in customer data than technical security.  This fundamental difference makes the concerns of the CCPA somewhat easier to address from a practical standpoint, as it is less technically intensive than the GDPR.  For example, GDPR Chapter IV’s lengthy technical requirements are not reflected in the CCPA.  There are no requirements for appointments of Data Protection Officers, codes of conduct, or certification mechanisms.

Another noticeable distinction between the two regulations concerns the duration for which a business may keep users’ data. The GDPR expressly requires that personal information is not stored for more than what is necessary for the business to provide its services or sell its goods. The CCPA does not provide any standard regarding the data retention period. Prior California law requires data be disposed of properly to ensure it is unreadable or undecipherable; but it does not dictate when. Cal. Civ. C. §1798.81.

The GDPR also requires businesses to allow consumers to update or complete their information. The CCPA does not have any equivalent provision, even though certain companies’ systems may allow users to complete or update their information. While the CCPA’s requirements that deletion can be requested may implicitly require businesses to delete inaccurate information, the CCPA does not clearly require a correction mechanism.

The CCPA also expressly authorizes companies to provide financial incentives to users to encourage data disclosure. Among the permitted financial incentives: a company may make payments to consumers as compensation for collection of their data, or offer different prices, rates level or quality of goods or services.  The CCPA however indicates that financial incentives a business may offer must be “directly related to the value provided to the consumer by the consumer’s data.” Cal. Civ. C. §1798.125(b)(1). The CCPA also provides that a business shall not offer financial incentives that are “unjust, unreasonable, coercive, or usurious in nature.” Cal. Civ. C. §1798.125(b)(4). This financial incentive provision appears to be in tension with the anti-discriminatory provisions of Cal. Civ. C. §1798.125(a)(1).  Thus, any financial incentives offered may need to be closely tied to an actual value provided.

Further, the CCPA requires a business to update their privacy policies at least once every 12 months and provide a list of information subject to the update, such as data subjects’ rights, the categories of information collected or the nature of the information sold to third parties. Cal. Civ. C. §1798.130(a).

As previously mentioned, CCPA does not become effective until January 1, 2020, and reports suggest there are likely to be at least some revisions before that deadline.  But until then, companies should consider reviewing their collection and use of consumer personal information and determine if any revisions to their practices and privacy policies are needed.

This blog post is only a summary and provides only general information regarding some notable portions of the CCPA.  It is not a complete discussion of obligations under the CCPA, and does not constitute legal advice upon which anyone may, or should rely.

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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JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

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Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

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How is your information shared?

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How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

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Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
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You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

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How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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There are different types of cookies and other technologies used our Website, notably:

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JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

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Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

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If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

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