Collector - October 2020 - 27

do, as landline usage has been in a freefall in
recent years-you could meet the threshold
right there. This is a blanket provision for all
cellphone numbers, not just numbers from
California residents. So when calculating
the 50,000 threshold, you would add the
number of California residents about which
you receive information in a year plus the
number of cellphone numbers you receive
in a year, without regarding whether the
cellphone number is used by a California
resident or not.
And if that doesn't push you over that 50,000
threshold, your website might. Many websites
collect IP (Internet Protocol) addresses
(cookies) from visitors, so even if the visitor
never specifically enters personal information
in your site, like their name on a contact page
or a credit card number on a payment page,
you may have still quietly collected information
from their computer or phone, which could
put you under the CCPA's purview.
"Often the people who ask me if the
CCPA applies to their business have no idea
if their website is collecting IP addresses,"
Coleman said. "I encourage them to go
back to their IT people or web hosting
company to find out."
If you do collect IP addresses through
your website, you need to know how many
you collect in a year for all consumers, not
just California residents.
If you run your own payment portal, you're
getting consumers' personal information
with every payment. And again, you may be
collecting IP addresses there too. If a thirdparty is running your payment portal, that
vendor is considered to be the entity collecting
the personal information and would have to
complete its own CCPA compliance calculation.
Coleman pointed out that it would not
be unusual to record an IP address when a
payment is made at a website to document
the authenticity of the payment should
someone question whether the payment
was fraudulent. Coleman has received
IP address information from collection
agencies and law firms as verification from

clients that the debt is owed and not the
result of identity theft.
So when you ask your IT person or web
hosting company whether you collect IP
addresses for people who visit your website,
make sure to ask about whether you record
IP addresses for payments made through
your payment portal.
However, even if you don't make the
50,000 threshold, if you collect for a client
that meets the threshold, you are a service
provider subject to the CCPA for the
accounts from that client.
Coleman added that if a vendor's client
is subject to the CCPA, then the vendor is
subject to the CCPA as a service provider
and essentially all the same rules apply.

TO RECAP: IT'S NOT AS CLEARCUT AS YOU MIGHT THINK
Coleman suggested businesses ask
themselves the following questions:
*	 How many IP addresses do you collect
each year from your website?
*	 How many accounts owed by California
residents are referred annually?
*	 How many accounts referred annually
contain a cellphone number (not
limited to phone numbers from
California residents)?
When you're reviewing your accounts for
this calculation, don't forget that some accounts
have co-debtors, like a married couple. You
can also collect information from a parent or a
girlfriend/boyfriend making a payment. These
people will also have to be accounted for as you
determine if you meet the threshold.
"In general, I think CCPA compliance is
a blind spot for many companies, especially
companies outside of California," Coleman
said. "I think sometimes people are reluctant
to investigate if they need to comply because
they are afraid of what they will find out."
If your head is in the sand, it's time to take
it out and look around.
Anne Rosso May is ACA International's
communications director and editor-in-chief.

LEARN MORE
ACA International members can listen to June Coleman, managing attorney
for the California office of Messer Strickler Ltd., and Mike Etmund, attorney
for Moss & Barnett, review the CCPA in this episode of the ACA Huddle:
www.acainternational.org/products/the-huddle-6-17-2020.

COLLECTOR 10.20

1

Even if your company is
not located California, you
might still be subject to the
CCPA.

2

Check to see how many IP
addresses (cookies) you
collect each year from your
website.

3

When you're reviewing
your accounts for
the 50,000 calculation
of consumers' personal
information, don't forget that
some accounts have codebtors, like a married couple.
27


https://www.acainternational.org/products/the-huddle-6-17-2020

Collector - October 2020

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