California’s Attorney General will hold public forums to seek input on California's Consumer Privacy Act (CCPA). The first of these public forums is scheduled for today in San Francisco, with others scheduled throughout California in January and February. Future dates and times can be found here. The public forums are part of the rulemaking process, which the Attorney General's office is undertaking.

The Act aims to give consumers control of their data. It requires companies that are covered by the Act to disclose certain information about the consumer’s data: what data the company collected, where that data came from, and with whom that data has been shared. The consumer may also request that their data be deleted and not sold to other entities. Under the Act, signed into law on June 28, 2018, the Attorney General is tasked with enforcement.

This law was passed very quickly. According to the Act’s legislative history, it was revived from an inactive file on June 21, 2018, which is only a week prior to the Governor signing it into law.

insideARM Perspective

This law may have a significant impact on how the industry gets, uses, and shares consumer data in California. According to section 1790.140(c), the law applies to businesses that meet one or more of the following thresholds: have an annual gross revenue over $25M; buy, sell, receive or share for commercial purposes the data of 50,000 or more California residents; or derive 50% of revenue from “selling” personal data of California residents. This likely puts many skip tracers and larger collection agencies, which receive consumer data from creditors, into the purview of this law. These public forums offer the industry the ability to provide input to the Attorney General as the rules regulating the CCPA are being formed, so participation is encouraged.

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