February 17, 2020

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Modifications Under CCPA To Receipt of Consumer Requests

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.

Copyright © 2020, Sheppard Mullin Richter & Hampton LLP.

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Liisa Thomas, Sheppard Mullin Law Firm, Chicago, Cybersecurity Law Attorney
Partner

Liisa Thomas, a partner based in the firm’s Chicago and London offices, is Co-Chair of the Privacy and Cybersecurity Practice. Her clients rely on her ability to create clarity in a sea of confusing legal requirements and describe her as “extremely responsive, while providing thoughtful legal analysis combined with real world practical advice.” Liisa is the author of the definitive treatise on data breach, Thomas on Data Breach: A Practical Guide to Handling Worldwide Data Breach Notification, which has been described as “a no-nonsense roadmap for in-house and...

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Craig Cardon serves as Co-chair of Sheppard Mullin’s Privacy & Data Security Group and as the International Liaison for the firm’s China offices. Craig is a partner in the Entertainment, Technology and Advertising and the Intellectual Property Groups in Sheppard Mullin's San Francisco and Century City offices.

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Craig enjoys a broad advertising, privacy and ecommerce focused practice. He primarily represents brands, retailers, ad agencies, ad networks and other business involved in advertising, marketing and the data associated with it.  

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Rachel Hudson, Lawyer, Sheppard Mullin, Intellectual Property Practice Group
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Rachel Tarko Hudson is an associate in the Intellectual Property Practice Group in the firm's San Francisco office.

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Rachel advises clients in the retail, technology, media, and other industries in online and mobile e-commerce transactions and vendor agreements, intellectual property licensing, commercial and development agreements, and other transactional matters. She assists clients in complying with domestic and international privacy laws, clearing advertising campaigns, conducting contests and sweepstakes promotional initiatives, and...

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Rebecca Mackin is an attorney in the Intellectual Property Practice Group in the firm's Chicago office.

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