September 18, 2021

Volume XI, Number 261

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California Attorney General Issues Summary of CCPA Enforcement Actions and Launches Consumer Privacy Interactive Tool

The California Attorney General (“AG”) recently released a summary of enforcement actions the agency brought against companies in violation of the CCPA since enforcement of the Act began on July 1, 2020. The summary provides 27 illustrative examples of instances in which the AG sent notices of alleged noncompliance with the CCPA and how each company cured the alleged noncompliance.

The table below sets forth the types and number of alleged CCPA violations in the enforcement actions summarized by the AG:

Alleged CCPA Violation

Number of Times Alleged

Non-Compliant Privacy Policy

14

No “Do Not Sell My Personal Information” Link/
Non-Compliant Opt-Out of Sale Process

9

Lack of CCPA Request Methods

6

No Notice to Consumers at Time of Collection

5

Failure to Disclose Sale of Personal Information (Ad Tech)

5

Non-Compliant Service Provider Contracts

2

Lack of Opt-In to Sale Mechanism for Minors

1

No Notice of Financial Incentive

1

Verification Requirement for Opt-Out of Sale Requests

1

Account Creation for Verification of CCPA Requests

1

Untimely Responses to CCPA Requests

1

Charging Fees for CCPA Requests

1

Defective CCPA Request Methods/Lack of Toll-Free Number

1

Non-Compliant Authorized Agent Verification Method

1

The AG also launched the Consumer Privacy Interactive Tool, which allows California consumers to draft a notice of noncompliance to businesses that do not post an easy-to-find “Do Not Sell My Personal Information” link on their website. The AG has indicated that the agency hopes to expand the tool to include other CCPA violations in the future.

Copyright © 2021, Hunton Andrews Kurth LLP. All Rights Reserved.National Law Review, Volume XI, Number 204
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About this Author

In today’s digital economy, companies face unprecedented challenges in managing privacy and cybersecurity risks associated with the collection, use and disclosure of personal information about their customers and employees. The complex framework of global legal requirements impacting the collection, use and disclosure of personal information makes it imperative that modern businesses have a sophisticated understanding of the issues if they want to effectively compete in today’s economy.

Hunton Andrews Kurth LLP’s privacy and cybersecurity practice helps companies manage data and...

212 309 1223 direct
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