How can legal counsel facilitate CCPA compliance?
Most practically, businesses should stay abreast of CCPA updates and amendments. Several amendments have been proposed by California legislators, and a new initiative (colloquially named “CCPA 2.0”) may appear on the November ballot. Furthermore, the attorney general’s regulations are expected to be finalized before the July 1 enforcement date.
Internally, businesses should conduct a data mapping exercise to identity the data they are collecting and how it is being used. A data inventory and assessment is essential to a CCPA compliance program.
Businesses also need to assess resources and infrastructure to ensure proper compliance. Among other measures, businesses should identify key stakeholders and create project teams, earmark funds for compliance, document a plan, update privacy policies and other required notices, and implement procedures for handling consumer requests.
Businesses should also review and update data breach and incident response controls, as well as the contracts of vendors and other service providers.
Above all, businesses should not view compliance as a once-and-done project. Businesses must conduct periodic assessments and review results to gauge ongoing compliance with the CCPA’s evolving requirements.