The CCPA is a landmark consumer privacy law that requires significant changes for businesses, including those operating online, in regard to personal data of California residents. The law will go into effect January 1, 2020 and the Attorney General will begin enforcement on July 1, 2020.

Like the General Data Protection Regulation (GDPR) in the European Union, the CCPA is designed to give users more control of their personal data. Generally, companies who do business in California, share data with California businesses or have employees in California should review this information to determine whether the CCPA applies to them.

Immediate Action Items:

If the CCPA applies to your business, here are some steps you should consider:

1. Be prepared to respond to consumer and employee data requests – know where your data is, where it came from and how it is being used.
2. Prepare for data access and deletion requests – have a system for tracking and replying to these requests and create two points of contact for consumers.
3. Have a system in place to track consumers who opt-out of data selling.
4. Update service-level agreements with third-party data processors.

Prepare necessary internal policies and train your employees. This is an opportunity to create clear and simple data flows and train employees to follow them.

Katie Duffy is a member of our Employment and Labor Practice Group. She is a certified Informational Privacy Professional and is certified through the Massachusetts Commission Against Discrimination’s Certified Discrimination Prevention Program. Katie works with clients to develop a positive and productive workplace through strong policies and trainings and by conducting comprehensive and fair investigations when necessary. ​Katie can be reached at kduffy@bdblaw.com.

Paul Filon is a registered patent attorney. Clients range from domestic and international companies to individual inventors and authors. He helps clients from idea formation through product development, commercialization and beyond. Paul handle issues involving all aspects of intellectual property such as patents, trademarks, copyrights, trade secrets, licensing and the Internet. Navigating the complex bureaucracies of the United States Patent and Trademark, and the United States Copyright Offices, often leaves businesses and inventors feeling frustrated. It is my job to alleviate this stress by advocating for my clients to achieve the best possible protections for their ideas and inventions at the best possible value. Paul can be reached at pfilon@bdblaw.com.