The CCPA states that a service provider must be contractually prohibited from “retaining, using, or disclosing the personal information [provided to it by a business] for any purpose other than for the business purposes specified in the contract for the business . . . .”[1] That prohibition, however, may not apply to information once
GT Shareholders Gretchen A. Ramos, Co-Chair of the Global Data Privacy & Cybersecurity Practice, and Darren Abernethy will present the CLE webinar, “The Final CCPA Regulations: What You Need To Know,” March 2 at 12:00 p.m. PT. The webinar will provide an overview of key takeaways from the finalized proposed
On Jan. 27, 2023, the California Attorney General announced his office is investigating and sending letters to businesses in the retail, travel, and food industries with popular mobile apps that allegedly are not in compliance with the California Consumer Privacy Act (CCPA) by failing to offer a consumer opt-out mechanism for sales, or honor rights
A review of the Fortune 500 conducted approximately one year after the CCPA went into effect showed that 21 percent of websites included a “Do Not Sell My Personal Information” link; 78.6 percent of websites did not include a link to opt out of the sale of personal information.[1] Over the past year, that
The CCPA requires businesses that sell personal information to explain that consumers have a right to opt-out of the sale[1] and provide a clear and conspicuous link on their homepage titled “Do Not Sell My Personal Information” that takes the consumer to a mechanism that permits them to exercise their opt-out right.[2] If
The regulations implementing the CCPA require that a business verify the identity of a consumer that submits a specific-information access request to a “reasonably high degree of certainty.”[1] The regulations provide as an example matching three pieces of personal information provided by the consumer with three pieces of personal information maintained by the business
The CCPA and its implementing regulations identify six types of information requests that a consumer can submit to a business. As the first five requests ask that a business respond with broad information about the type of information collected (as opposed to the actual information itself), they are often referred to as category-level access requests.
In order to help businesses understand and benchmark industry practice, Greenberg Traurig attorneys analyzed the publicly available privacy policies of companies within the Fortune 500.[1] As of October 2022 – nearly two years after the CCPA took effect – 71% of companies had updated their privacy policies to account for the CCPA.[2] It
After Europe blazed the trail by passing the sweeping General Data Protection Regulation (“GDPR”) in 2016, California followed closely in the footsteps of European efforts by passing the most comprehensive data privacy law in the United States, the California Consumer Privacy Act (the “CCPA”). Effective January 1, 2020, the CCPA provided a number of obligations
Some modern data privacy statutes mandate that organizations allow third parties – who are authorized by a data subject – to submit access, deletion, correction, or other requests on behalf of a consumer. Such third parties are sometimes referred to as “authorized agents” – a term created by the regulations implementing the CCPA. The following