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California Consumer Privacy Act

Client Alert

Client Alert
August 19, 2019

The California Consumer Privacy Act (CCPA), a privacy rights and consumer protection bill for residents of California, United States, goes into effect in January 2020. Familiarity with the CCPA is a necessity for many Florida businesses, because it applies to any company, regardless of its location, that meets any of certain designated criteria. Given the short remaining time before the CCPA goes into full effect, it is important for in-house counsel to be aware of its key aspects:

• The CCPA applies to any entity that has gross annual revenue of $25 million (regardless of whether the entity has a California office, or whether that revenue comes from business transactions with a California nexus), or deals in the personal information of 50,000 or more California consumers. The act also applies to companies that derive more than 50% of their annual revenue from selling the personal information of California residents or businesses. Merely sharing common “branding” with a company that meets one of these criteria subjects a business to the act’s requirements.
• It requires businesses to feature a “do not sell my personal information” link on their websites, so that website visitors may opt out of any such sales.
• The CCPA also adds a number of new substantive requirements as to what must be included in a privacy notice or policy.
• The law requires compliance with its provisions as of January 2020, which means immediate action is required to meet that deadline. Violations of the CCPA are subject to enforcement by the California Attorney General’s office, which can seek civil penalties of $2,500 for each violation or $7,500 for each intentional violation after notice and a 30-day opportunity to cure have been provided.

The CCPA is of course far more detailed and intricate than this brief overview might suggest. If you are interested in learning more about the fuller set of requirements – and recommended action items for your company -- please contact Phil Stein, Litigation Practice Group Leader, at


Philip R. Stein

Philip R. Stein

Partner, Litigation Practice Group Leader