No. Both the CCPA and the GDPR provide individuals with a right to request access to their personal information and a right to request the deletion of their personal information. As a result, businesses that field rights...more
Not necessarily. As an initial matter, employees that are residents of California will not qualify as full “consumers” under the law until January 1, 2021....more
Likely no. Neither the CCPA nor the proposed regulations explicitly address the issue of imposing fees or costs on consumers for responding to requests for access or requests for deletion. However, the CCPA does prohibit...more
As one of the oldest and most recognized data privacy and security practices, we have had the honor of helping dozens of companies set up and evolve their data privacy programs over the past decade. That experience has given...more
No. The CCPA grants to consumers “the right to request that a business delete any personal information about the consumer which the business has collected from the consumer.” Nothing within the CCPA prohibits a business from...more
Report on Supply Chain Compliance 2, no. 20 (Oct. 24, 2019) - The right to be forgotten is a statutory right under the GDPR, and since the implementation of that regulation in May 2018, there have been several requests for...more
Probably not. The term “personal information” is defined by the CCPA as “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with...more
Consumer privacy laws enacted on the other side of the country could have big implications for businesses here in North Carolina. On January 1, 2020, the California Consumer Privacy Act (CCPA) will take effect. This is a...more
Loyalty programs are structured in a variety of different ways. Some programs track dollars spent by consumers, others track products purchased. Some programs are free to participate in, others require consumers to purchase...more
Yes. The CCPA states that people have a right to request that a business “delete any personal information about the consumer which the business has collected from the consumer.” Although the CCPA does not define what it...more
No. The scope of the right to be forgotten under the CCPA and the GDPR differ in three important ways. First, the CCPA states only that a business may have to delete the information that it obtained “from” the consumer....more
No. The CCPA states only that a business may have to delete the information that it obtained “from” the consumer that submits the right to be forgotten request. As a result, if a business obtained information from two...more
Federal US News - FTC Takes Action Against Companies Falsely Claiming Compliance With International Privacy Agreements - The FTC reached a settlement with a background screening company over allegations it falsely claimed...more
Probably not. The CCPA does not specifically state that a right to be forgotten request is, itself, exempt from the obligation to delete a consumer’s information, but maintaining the right to be forgotten request would...more
The new California Consumer Privacy Act of 2018 (CCPA) will come into effect January 1, 2020. In most situations, nonprofits won’t be subject to the law—but in some cases they necessarily will be and/or will otherwise need to...more
The new California Consumer Privacy Act of 2018 (CCPA) will come into effect January 1, 2020. By turning attention to the issue now, cannabis companies can ensure compliance with the new law without significant business...more
The California Consumer Privacy Act ("CCPA") was enacted in early 2018 as a political compromise to stave off a poorly drafted, and plaintiff’s friendly ballot initiative. Although the CCPA is scheduled to go into force in...more
Why does this topic matter to organisations? EU data protection law provides data subjects with a wide array of rights that can be enforced against organisations that process personal data. These rights may limit the...more
...On April 4, 2019, California Assembly Member Wicks proposed sweeping changes to bill AB 1760, effectively repealing the California Consumer Privacy Act of 2018 (CCPA) and replacing it with the Privacy for All Act of 2019...more
The California Consumer Privacy Act ("CPPA") was enacted in early 2018 as a political compromise to stave off a poorly drafted, and plaintiff’s friendly ballot initiative. Although the CPPA is scheduled to go into force in...more
There are significant differences between the version of the CCPA that was first proposed as a ballot initiative in 2017 and the version of the CCPA that was ultimately passed by the state legislature in 2018. In general, the...more
California recently enacted the California Consumer Privacy Act (“CCPA”) which calls for companies to fundamentally change certain practices relating to the collection and use of personal information. Similar to the European...more