CCPA Timeline, Enforcement, and Checklist

B2B marketers: July 1 enforcement begins amid Covid-19. The final draft of CCPA (California Consumer Privacy Act) regulation was submitted by the Attorney General (AG) of California to the Office of Administrative Law (OAL) for review on June 1, 2020. OAL generally takes a period of a month for review and implementation of any law. Yet, there is no news of changing the enforcement date of CCPA. Enforcement will likely come into effect from July 1, 2020. Organizations that have planned CCPA compliance based on the March 2020 draft would be in a good position to comply with the new draft positioned on June 1st, 2020 and they will need to make only a little effort for CCPA compliance when CCPA is enforced.

Important CCPA Timelines:

• October 12, 2017 – Privacy ballot initiated.
• June 28, 2018 – CCPA, AB 375, signed into law.
• August 31, 2018 – An amendment bill approved.
• January 1, 2020 – Organizations are required to comply with CCPA. CCPA goes in effect.
• January 29, 2020 – Ad industry requests delay in CCPA enforcement deadline.
• Feb 10, 2020 – Published a “first notice of modifications” to CCPA.
• March 27, 2020 – Published a “second notice of modifications” to CCPA.
• June 1, 2020 – Attorney General submitted the final proposed CCPA regulations to OAL.
• July 1, 2020 – Latest possible date for CCPA enforcement to begin.
• July 2, 2020 – Latest possible date for California’s Attorney General to publish CCPA regulations.

CCPA Enforcement:

California’s consumers have a very powerful tool in their hand against the Organization that uses personal information of Consumers. Violation of CCPA regulations may land Organizations/businesses in huge financial penalty. So considering the huge economic repercussions in violation of CCPA, organizations are recommended to work with law counsels to make sure about CCPA compliance by July 1, 2020.

CCPA Checklist:

Businesses that collect consumers’ personal information or do business in California must abide by certain rules and regulations defined in CCPA. Businesses should have a quick advance CCPA checklist that can help in avoiding CCPA violations. Below checklist points can help businesses to comply with CCPA regulations.

• ✔  Determine if the Business qualifies for CCPA.
• ✔  Organize personal information of consumers.
• ✔  Update website home page.
• ✔  Update website privacy policy.
• ✔  Create policies to manage and delete consumers data on request.
• ✔  Create Policy to provide minor “right to opt in”.
• ✔  Create a Training module and train employees on CCPA.
• ✔  Have policy for third party service providers to restrict uses of personal information as per CCPA regulation
• ✔  Determine what information is collected from California consumers and for what purpose.
• ✔  Define a process and identify individuals who are responsible for handling consumer information.
• ✔  Define a documented process (Give at least two alternate ways for consumers to contact) and identify individuals who are responsible for responding to consumers’ request.
• ✔  Provide ‘right to equal service’ and ‘equal price’ to the California consumers.
• ✔  Create a quick and robust response plan.
• ✔  Create a policy to delete data on request as per CCPA regulation.

RightWave assists its customers in complying with international regulations that impact B2B digital marketing. For more information, Contact RightWave.

References:

1. Morgan Lewis,  CCPA Compliance Requirements Checklist
2. Final Text of Regulations – Title 11. Law – Division 1. Attorney General – Chapter 20. California Consumer Privacy Act Regulations, FINAL TEXT OF REGULATIONS
3. Proposed Regulations Package Submitted to OAL, California Consumer Privacy Act (CCPA)
   
4. 17 April 2020, by David O. Klein, CCPA Enforcement Date Remains July 1, 2020