CISO White Paper On CCPA Compliance Guides Cybersecurity Leaders In Retail And Hospitality

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Fox Rothschild LLPCISO members of the Retail & Hospitality Information Sharing and Analysis Center (RH-ISAC) published a white paper to help cybersecurity leaders in retail and hospitality prepare for compliance with the California Consumer Privacy Act (CCPA).

Key recommendations from the white paper:

  • Consider contract language that prevents third-parties from selling personal information sold to them unless the consumer has received explicit notice and has been provided the opportunity to exercise their right to opt-out
  • Consider expanding cookie opt-out functionality to go beyond Interest Based Advertising/Online Behavioral Advertising
  • Geotracking of company vehicles may be considered tracking of consumers
  • Conduct process-centric data mapping identifying all internal and external business processes that process personal information and data flows
  • Establish a governance program
  • Appoint stakeholder(s) to be in charge of CCPA compliance (see photo below for potential candidates)
  • Appoint stakeholder(s) to be in charge of data access/deletion requests
  • Involve stakeholders from all relevant departments
  • Gain buy-in by emphasizing the additional benefits of performing a data mapping/inventory beyond privacy

Read the full white paper.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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