[co-author: Zach DeFelice]


As the CCPA’s effective date approaches, businesses are actively monitoring how companies will update their privacy notices to comply with the new disclosure requirements of the Act. While many companies are prepared to update their own privacy notices at the end of the year, policies that are preemptively changed before year-end are being reviewed and scrutinized for trends and signs of any industry standard practices surrounding such things as the disclosure of the “sale” of information or the collection of information by “enumerated category.”

In order to help companies understand and benchmark industry practice, BCLP analyzed a random sample of the privacy notices of Fortune 500 companies.1 Based upon that sample it appears that approximately 13% of companies have released CCPA-revised privacy notices. As a result, releasing updated privacy notices remains the exception and not the rule. Indeed, on average it has been 649 days since companies in our sample population had last updated their privacy notices.

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. Using a computer random number generator, BCLP selected 6% of the companies listed among the Fortune 500 in 2019. Revenues for the selected companies ranged from $85 billion to $5 billion. While BCLP did not conduct statistical analysis to determine whether the sample selected accurately represented the range of businesses in the United States, the sample contained companies focused on retail, financials, food, agriculture, manufacturing, entertainment, and energy.

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