News & Analysis as of

Subject Access Request (SAR) California Consumer Privacy Act (CCPA)

BCLP

Are businesses required to offer the same methods for submitting DSR requests under the CCPA as they are under the GDPR?

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No. Much like the GDPR, the CCPA gives consumers certain rights over their data. In particular, California residents have the right to request access to their personal information, the right to request the deletion of...more

BCLP

Are pharmaceutical companies offering access and deletion rights?

BCLP on

Yes. Pharmaceutical companies within the Fortune 500 are universally notifying Californians of their right to request access to, or the deletion of, their personal information....more

BCLP

Do companies have to flow down access requests to service providers that maintain redundant copies of information?

BCLP on

No. When a business receives a request from a consumer to access the personal information that the business has “collected,” it must decide whether to grant the request or to deny it based upon one of the exceptions to...more

BCLP

Are businesses required to create a policy or procedure for handling access requests?

BCLP on

No. While some businesses decide to create a written policy or procedure for handling access requests, other businesses decide that such a policy is unneeded....more

BCLP

How much time does a company have to respond to an access request?

BCLP on

The CCPA requires that a business “deliver” the information that is required to be produced under the Act within “45 days of receiving a verifiable consumer request.” The 45 day time period can be extended by an additional 45...more

BCLP

In response to an access request, does a company have to produce all of the information that it has about an individual?

BCLP on

The CCPA requires a business to respond to an access request by disclosing all information that it has “collected” about a consumer in the previous 12 months. Unlike the CCPA’s treatment of a business’s obligation to delete...more

Dorsey & Whitney LLP

Developments from California: AG Estimates Costs of CCPA Compliance as CCPA Authors Contemplate Round II

Dorsey & Whitney LLP on

The California Attorney General recently published a report assessing CCPA compliance costs.  The report attempts to quantify the monetary value of consumers’ personal data, and estimates the total value of personal data...more

Eversheds Sutherland (US) LLP

New CCPA amendments bring clarity prior to the January 1, 2020 deadline

In the run-up to January 1, 2020, the California legislature and Attorney General are rushing to provide clarity to the California Consumer Privacy Act of 2018 (CCPA) - and businesses are rushing to interpret and implement...more

BCLP

CCPA Privacy FAQs: If a business receives an access request, does it have to provide information that it collected more than a...

BCLP on

No. The CCPA contains four references to the obligation of a business to, in response to an access request, provide the “specific pieces of personal information” that it has collected about a California resident. Each of...more

Holland & Knight LLP

California Attorney General Releases Draft Regulations on the California Consumer Privacy Act: New Requirements Have Potentially...

Holland & Knight LLP on

The California Attorney General Xavier Becerra on Oct. 10, 2019, released the proposed text for the California Consumer Privacy Act Regulations (Regulations). The Regulations are intended to guide businesses on CCPA...more

BCLP

CCPA Privacy FAQs: Can a company be sued under the CCPA for failing to honor an access request?

BCLP on

No. Section 1798.150 of the CCPA permits consumers to “institute a civil action” only where consumer “nonencrypted or nonredacted personal information, as defined in subparagraph (A) of paragraph (1) of subdivision (d) of...more

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