Collector - April 2020 - 23

"The CCPA requires businesses to review and update
their privacy policies at least every year."

data points maintained by the business,
which the business has determined
to be reliable.
Stevens said verifying a consumer's
identity is an example of what businesses can
prioritize to comply with the CCPA.
Consumer identity verification has
very specific guidelines in the proposed
regulations, he said, and it is also required
under the statute.
"Therefore, it should be a priority,"
Stevens said. "Every business must make
its own determinations. Most of our
clients are treating the entirety of the
proposed regulations as if they needed
to meet them by Jan. 1. They are taking a
conservative approach."
Businesses that don't fall under the criteria
to comply with the CCPA can look at it as a
platform for what may come in their states
or at the federal level.
"The CCPA is held up as the example all
other states want to follow," Coleman said.
Stevens said many of Mac Murray and
Shuster's clients are wondering if the CCPA
is the start of a broader law at the federal
level they need to think about, or is it a oneoff for California?
"What I tell them is I think this is actually
a continuation of a broader trend globally,"
Stevens said.

THE VALUE IN EVALUATING
DATA PRIVACY POLICIES
Regardless of how the CCPA may change in
the future and the likelihood of additional
state laws on data privacy, there is a lot of
value in evaluating your data policies and
procedures and how your business stores
and processes consumers' data.
For example, Stevens said one client
working on compliance steps for the

COLLECTOR 04.20

CCPA found deficiencies in their system
to store consumer data.
"Going through this exercise allowed
them to find ways they could use their
consumer data in ways they weren't
previously, in compliance with the law,"
he said.
The CCPA requires businesses to review
and update their privacy policies at least
every year.
Stevens recommends that businesses
train an employee or team of employees
how to review the policies for compliance
going forward.
"Companies that are strictly focused
in the U.S., I am finding, need a lot more
time and have to invest a lot more energy
because they've never gone through such
a deep privacy analysis before," Stevens
said. "I think this is a start of a wave.
Companies, not just Californians, really
need to think about how they implement
privacy across the board and as part of
their day-to-day business practices."
In today's privacy-focused world,
consumers expect their data is going to be
protected, so the more you know about
the data you have and your policies and
procedures surrounding it, the better.
This data mapping process also
enhances companies' preparation for, and
protection from, a data breach, according
to Stevens.
"My general piece of advice is don't
get discouraged about how long it takes,
and there is real value in going through
this exercise," Stevens said. "It's best to
start thinking about those steps now to be
prepared for the future."
Katy Zillmer is ACA International's
communications specialist.

1

The CCPA requires
businesses that fall under
the law to review their privacy
policies annually. You may
also want to develop privacy
notices for your letters and to
post on your websites.

2

Don't do business in
California? It's still
important to take steps to
protect consumers' data and
be prepared for potential data
breaches.

3

The CCPA is likely to serve
as a model for other state
data privacy laws or a broader
law at the federal level.

23



Collector - April 2020

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