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Volume X, Number 218

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Turn On the Camera Part Three: Fulfilling CCPA Training Obligations in the Face of COVID-19

As many who have been tracking CCPA are aware, the law requires training employees who handle consumer inquiries, and ensuring that employees understand how to help consumers exercise their rights. Since most of those rights requests are arriving by web page, email, and phone, it is unlikely that rights requests will slow in the face of COVID-19. Indeed, it is possible that they may increase. Employees will thus still need training, something many companies had anticipated doing in-person.

In-person training is particularly useful to ensure employees adequately understand and digest CCPA requirements, and many coordinate with their law firms to put together such sessions. These trainings typically address not just CCPA-related privacy training requirements, but also training required under other privacy laws (GDPR, GLBA, HIPAA, to name but a few) and industry guidelines. Potential restrictions on group gatherings, corporations limiting travel, and employees working remotely puts in-person in jeopardy.

Rather than avoid privacy training, companies can tweak their existing training plans and make use of the myriad of virtual platforms available in this modern age. When doing so, companies do not have to sacrifice interactivity. As those who regularly use interactive tools can attest, they provide several useful features that can help gauge effectiveness of training. Chief among these is the simple video camera. For companies who have a culture of “camera off,” now is the time to shift to “camera on.”  Training programs should still, as would have been the case with in-person training, focus on measurable success. Do employees understand how to direct consumers to exercise their rights? Do employees who are gathering information know where to look? These issues and others should be covered in training.

Putting it Into Practice: As companies map out their CCPA training plans, they can work with legal counsel to move towards -effectively implemented, interactive- virtual training in light of COVID-19. This can help prepare for rights request responses and otherwise address privacy training requirements.

Copyright © 2020, Sheppard Mullin Richter & Hampton LLP.National Law Review, Volume X, Number 73


About this Author

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

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...


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.

Areas of Practice

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.  

Rachel Hudson, Lawyer, Sheppard Mullin, Intellectual Property Practice Group

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

Areas of Practice

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...