Comments to the final California Consumer Privacy Act regulations asked how franchisor/franchisee compliance with CCPA works?

• Does CCPA apply to the franchisee for collecting data on behalf of the franchisor?
• How is the franchisor supposed to calculate its revenues for the purpose of the $25 million applicability threshold?

The California Attorney General Responded:

•  The regulation provides general guidance for CCPA compliance.
• Further analysis is necessary before proposing a regulation that provides guidance specific to the franchisor/franchisee relationship and the statutory definition of “business” in CCPA.

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