Modifications Under CCPA To Receipt of Consumer Requests

Sheppard Mullin Richter & Hampton LLP

One of the CCPA amendments that has gone to the governor’s desk is AB 1564, which addresses the methods companies must make available to consumers to exercise their rights under CCPA. Businesses which operate exclusively online and have direct relationships with their consumers can (1) provide an email address for consumers to submit requests, and (2) if they have a website (which presumably all online businesses would!), have a method for consumers to submit requests on that website. It is not clear from the amendment if listing the email address on the website would fulfill the latter requirement, or if the intent is for companies to have an online form on their websites where requests can be submitted.

This modifies the existing version of CCPA, where companies must make available to consumers two or more methods for submitting their rights requests under CCPA “including, at a minimum, a toll-free telephone number, and if the business maintain an Internet Web Site, a Web Site address.” (California Civil Code §1798.130(a)(1)) (emphasis added).

Putting it Into Practice: This amendment may provide some limited relief to companies for methods of receiving CCPA-related requests.

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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