The California Consumer Privacy Act ("CCPA") was enacted in early 2018 as a political compromise to stave off a poorly drafted, and plaintiff’s friendly ballot initiative. Although the CCPA is scheduled to go into force in early 2020, there is a great deal of confusion regarding the requirements of the CCPA, including the degree to which it aligns with other privacy regulations such as the European General Data Protection Regulation (“GDPR”).
To help address that confusion, BCLP published the California Consumer Privacy Act Practical Guide, and is publishing a multi-part series that discusses the questions most frequently asked by clients concerning the CCPA.
United States federal data privacy laws apply to specific industry sectors (e.g., financial institutions, health care providers, or educational institutions). The statutes that require that a privacy notice be provided within those sectors do not mandate that the notice be distributed online.
In comparison, while the European GDPR requires that a company provide a privacy notice when it collects information from an individual , that requirement does not mandate that the privacy notice be displayed online.3
1. See 6 Del.C. § 1201C.
2. CCPA, § 1798.130(a)(5).
3. GDPR, Article 13 (4)