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In order to help businesses, understand and benchmark industry practice, Greenberg Traurig LLP analyzed the privacy policies of companies within the Fortune 500. As of December 2020, there was significant divergence between the rates at which companies in different industry sectors had updated their privacy policies to account for the CCPA. While all of the members of some industries (e.g., software, retail, and insurance) had updated their privacy policy, few of the members of other industries (e.g., architecture and engineering, electricity generation, and certain manufacturing areas) had done so. The following chart provides a general sense regarding the level of divergence with each column representing a separate industry sector:

Whether a company has updated its privacy policy for the CCPA is not necessarily indicative of whether the company is, or is not, complying with the statute. For example, companies in a particular industry sector (e.g., mining) may not collect personal information about California residents and, as a result, may not be required to provide privacy policies.