News & Analysis as of

Incentives Data Collection

McDermott Will & Emery

[Webinar] 2023 Enforcement Outlook Series: Protecting Your Business Against Non-Compliance and DOJ Penalties - March 23rd, 12:00...

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During speeches earlier this month, Deputy Attorney General Lisa Monaco and Assistant Attorney General for the Criminal Division Kenneth A. Polite, Jr. announced significant changes to the way DOJ evaluates corporate...more

Foster Garvey PC

What Hospitality Businesses With a Loyalty Program Can Do Now to Stay Compliant With the California Consumer Privacy Act

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To celebrate Data Privacy Day, on January 28, California Attorney General Rob Bonta announced an investigative sweep of businesses offering loyalty programs in California. This should come as no surprise, as Attorney General...more

Fisher Phillips

4 Takeaways for Businesses as California AG Targets Loyalty Rewards Programs

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The California Attorney General put loyalty rewards programs directly in his sights when he recently announced an “investigative sweep” of a number of businesses operating such programs in state. While it is lawful for...more

Rothwell, Figg, Ernst & Manbeck, P.C.

Heads-Up to Any Companies with Loyalty Programs –They Count as “Financial Incentives” for Purposes of the CCPA

On Friday, January 28, 2022, the California Office of Attorney General issued a press release announcing that California DOJ sent notices alleging non-compliance with the California Consumer Privacy Act (CCPA) to a number of...more

Ballard Spahr LLP

Financial Institutions Must Assess Whether They Must Comply with CCPA Requirements for Financial Incentive Programs

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Last month, California Attorney General Rob Bonta released a summary of his office’s enforcement activity under the California Consumer Privacy Act (CCPA). Although the summary did not include company names, the summary...more

BCLP

Does the collection of contact information to transmit promotions or discounts count as a “financial incentive program” under the...

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The regulations implementing the CCPA define a “financial incentive” as any “program, benefit or other offering, including payments to consumers, related to the collection, retention, or sale of personal information.” Some...more

BCLP

If a business offers a financial incentive when collecting a consumer’s personal information, does it have to estimate the value...

BCLP on

No. The CCPA generally prohibits a business from “discriminat[ing]” against a consumer that chooses to exercise “any of the consumer’s rights” – i.e., the right of access, the right of deletion, or the right to opt out of...more

BCLP

Is a business required to provide a financial incentive in order to collect a consumer’s personal information?

BCLP on

No. The CCPA states that a business “may offer financial incentives” to a consumer for the “collection of personal information,” the “sale of personal information,” or the “deletion of personal information.”...more

Sunstein LLP

California Leads the Nation in Privacy Protection, But To Where?

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The California Consumer Protection Act (CCPA) is scheduled to take effect on January 1, 2020. In recent days: - The Governor of California signed into law seven CCPA amendments, - The California Attorney General...more

Womble Bond Dickinson

Hidden in Plain Sight: California Consumer Privacy Act of 2018 Signals a Path Forward for Data Collection

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Much has been made of California Governor Gavin Newsom’s recent endorsement of “data dividends”: payments to consumers for the use of their personal data. Common Sense Media, which helped pass the CCPA last year, plans to...more

Foley & Lardner LLP

Health Conscious? The EEOC Is Expanding Incentives for Employees’ Spouses

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Employee wellness programs are frequently a source of ulcer-causing angst for employers, but the Equal Employment Opportunity Commission (EEOC) is making moves to treat some of the underlying issues. Late last week, the EEOC...more

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