CCPA: What Agencies Need to Know (May 2019)

Read the full guidance: CCPA: What Agencies Need to Know 

 

On January 1, 2020, a sweeping new data privacy law will go into effect in the United States. The law, known as the California Consumer Privacy Act (CCPA), is the first of its kind in the country. The CCPA grants California consumers new rights to know about, access, delete, and opt out of the sale of personal information businesses maintain about them, and it imposes requirements on businesses to help fulfill the consumer rights the law creates.

The 4A’s offers this primer to agency management, in-house counsel, advertising executives, and others who operate in California or who interact with the personal information of California consumers. This primer seeks to provide an overview of the CCPA, the new rights and requirements it creates, and practical tips for agencies in structuring processes, policies, and contracts to comply with the law. We invite you to use this primer to guide your compliance exercises.

Agency representatives reading this primer should note that the CCPA’s terms may evolve based on potential future amendments to the law, regulations interpreting its provisions, and possibly even a new federal law that could preempt the CCPA altogether. The California Attorney General is preparing regulations that may help to clarify some of the CCPA’s more ambiguous terms. The descriptions set forth in this primer are therefore subject to change. Clarifying regulations to be issued by the California Attorney General as well as eventual CCPA enforcement actions will shed light on regulators’ interpretations of the law. We recommend that you seek legal advice regarding the ways in which the CCPA may impact you and your business.

Below we provide a summary of the substantive provisions of the CCPA with an eye towards the obligations it may pose on agencies related to the personal information they collect and process, both on behalf of clients and for their own purposes. We also provide practical notes and key takeaways along the way in an effort to draw out certain critical parts of the law.

 

Read the full guidance: CCPA: What Agencies Need to Know