On Aug. 11, 2022, the U.S. Consumer Financial Protection Bureau issued guidance indicating that financial institutions and service providers that fail to adopt sufficient data security measures to protect consumer financial data may violate the Consumer Financial Protection Act provision prohibiting unfair acts and practices.

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What types of documents, policies, procedures, and protocols should service providers consider putting in place to comply with the CCPA?

The written policies and procedures that service providers put into place to assist in their compliance with the CCPA differ depending upon several factors including the size of the service provider, the quantity of personal