Page 8 - SMRH Eye on Privacy 2019 Year in Review Brochure
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this data [be] appended to create a fuller profile of the child, which may then be used for future targeted marketing.” Meaning that the child has “lost control” of his or her information before being able to give consent.
PUTTING IT INTO PRACTICE: While the facts in this case may be unique, this decision shows the ICO’s concern with obtaining fully informed consent, especially in the area of sharing for marketing purposes.
CCPA
Proposed CCPA Regs Released, Comments Due Dec. 6
Posted on October 11, 2019
The California attorney general has released draft regulations for CCPA, giving companies further guidance on a variety of topics. The regulations are in draft, and comments are due to the attorney general’s office by December 6, 2019. The AGs office will also be holding a series of hearings across the state, on December 2 (Sacramento), 3 (Los Angeles), 4 (San Francisco), and 5 (Fresno). Among the many items that companies will be examining in more detail in the coming days, the regulations provide details about how to verify consumers and the need for website accessibility in the provision of notices. The proposal also calls on companies to acknowledge access and deletion requests within 10 days of receipt of such a request.
In its commentary to the regulations, the AGs office noted that since CCPA was passed it has hired over 20 new personnel, and has spent over $4,000,000 directly related to this new law.
PUTTING IT INTO PRACTICE: Companies and industry groups will have until December 6 to provide written comments about the regulations. We anticipate many will be made, and that the hearings will be well attended.
Modifications Under CCPA To Receipt of Consumer Requests
Posted on October 3, 2019
One of the CCPA amendments that has gone to the governor’s desk is AB 1564, which addresses the methods companies must make available to consumers to exercise their rights under CCPA. Businesses which operate exclusively online and have direct relationships with their consumers can (1) provide an email address for consumers to submit requests, and (2) if they have a website (which presumably all online businesses would!), have a method for consumers to submit requests on that website. It is not clear from the amendment if listing the email address on the website would fulfill the latter requirement, or if the intent is for companies to have an online form on their websites where requests can be submitted.
This modifies the existing version of CCPA, where companies must make available to consumers two or more methods for submitting their rights requests under CCPA “including, at a minimum, a toll-free telephone number, and if the business maintain an Internet Web Site, a Web Site address.” (California Civil Code §1798.130(a)(1)) (emphasis added).
PUTTING IT INTO PRACTICE: This amendment may provide some limited relief to companies for methods of receiving CCPA-related requests.
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