Collector - April 2020 - 20

GET INVOLVED
ACA International's
Washington Insights FlyIn is a critical opportunity
for members to get
involved with advocacy
at the federal level and
learn more about the
reach of laws such as
the CCPA.
Register at www.acainter
national.org to join ACA's
advocacy team May 1921 in Washington, D.C.
Attendees will hear from
legislative and regulatory
speakers and meet with
members of Congress
on the Hill.

20

The CCPA applies to certain businesses
that fall under one or more of the following
umbrellas:
*	 Annual gross revenues of more than
$25 million;
*	 Alone, or in combination, annually buy,
receive, sell or share for commercial
purposes the personal information of
50,000 or more California consumers,
California households or devices;
*	 Derive 50% or more of annual revenue
from selling consumers' personal
information.
Key requirements of the CCPA include:
*	 Businesses must disclose data collection
and sharing practices to consumers,
including what information is collected;
*	 Consumers have a right to request that
their data be deleted, although there
are exceptions that should apply to the
collections industry;
*	 Consumers have a right to opt out of
the sale or sharing of their personal
information; and
*	 Businesses are prohibited from
selling personal information of
consumers under the age of 16 without
explicit consent.
These are the factors that are set in stone,
so what's next?
Becerra's office has begun the process
of reviewing its proposed regulations,
considering public input received in
December 2019 and following comments
collected on updates to the proposed
regulations that were due Feb. 25, 2020.
Additional comments on a second round
of updates were accepted until late March.
During this period, the attorney general held
numerous public hearings in California.
California-based attorney June Coleman,
with Messer Strickler Ltd., expects that the
proposed regulations will be finalized and
published by June 2020, and she hopes they
will clarify some aspects of the new law.
The proposed regulations were created
to "operationalize the CCPA and provide
practical guidance to consumers and

businesses subject to the law," according to
the attorney general's office.
For example, the proposed regulations
(available here: https://www.oag.ca.gov/privacy/
ccpa) include additional steps for responding
to consumers' requests to delete their data or
understand how their data is being used or sold,
particularly for businesses that monetize data.
The attorney general's office cannot bring
an enforcement action under the CCPA until
six months after the publication of its final
regulations or until July 1, 2020, whichever
comes first.
Coleman suggests that affected businesses
may want to bear in mind that although the
law bars Becerra's office from bringing an
enforcement action until July 2020, the attorney
general may later decide to prosecute businesses
that did not comply between January and July.
Accordingly, businesses required to follow
the CCPA should consider undertaking
an immediate evaluation of their existing
policies and procedures and begin preparing
for the additional final proposed regulations.
Businesses may further wish to develop
privacy notices for their letters, privacy
policies to post on their websites, and letters
to respond to requests for information and
requests to delete information.
Coleman believes that many agencies have
concluded that they need not comply with
the CCPA, even though that conclusion is
wrong more times than not.
"The first question I get is: 'This does not
apply to me, right?'" she said.
Coleman notes that the CCPA provision
applying the law to any business that "[a]lone
or in combination, annually buys, receives
for the business's commercial purposes, sells,
or shares for commercial purposes, alone or
in combination, the personal information
of 50,000 or more consumers, households,
or devices" does not limit the scope of that
provision to devices located in California.
Under the CCPA, "device" means "any
physical object that is capable of connecting
to the internet, directly or indirectly, or to
another device."

ACAINTERNATIONAL.ORG


https://www.oag.ca.gov/privacy/ccpa https://www.oag.ca.gov/privacy/ccpa http://www.acainternational.org http://www.acainternational.org http://www.ACAINTERNATIONAL.ORG

Collector - April 2020

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