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ReadersSpeak

Time to prepare for California's new privacy law also certain obligations and liabilities for certain types
of service providers processing the data of a regulated
e wish to thank Alan Friel of the business, and other third parties.
BakerHostetler law firm, afriel@bakerlaw.com,
for sending us a note, which is excerpted "The California attorney general's office (CaAG), which
W below, about California's new consumer has exclusive authority to enforce the CCPA, excepting a
privacy legislation: narrow private right of action for data security breaches
that overlaps other existing California laws, may give
"In late June, the California legislature signed into law businesses and service providers some leeway in becoming
Assembly Bill 375 (AB 375) as the California Consumer fully compliant by the effective date.
Privacy Act of 2018 (CCPA), a privacy law, unprecedented
in the U.S., that grants California residents a broad range "Prudent companies will become familiar now with what
of European-like rights when it comes to their personal the law will require and start to work with their legal and
information (PI), effective Jan. 1, 2020. To be able to comply IT departments on compliance."
on the effective date, businesses will need to start record
keeping no later than Jan. 1, 2019, and likely will need to Share your insights
complete data mapping prior to that. For further explanation of this law, please see "Overview
of the California Consumer Privacy Act" by Josh Herndon
"Data inventorying and management vendors are on page 20.
scrambling to update their platforms to enable businesses
to do so, and the cost of such solutions is projected to How do you anticipate California's new privacy law will
be significant – $50,000 to $100,000 a year. Given that affect your company? Have you begun to prepare for its
processing an average of 138 credit cards a day, or enactment? Do you expect other states to pass similar
having an average of 138 unique website visits a day, or a laws? Do you have information about other developments
combination thereof and other data collection, is enough of concern to the payments community? Let us know at
to draw a business under the scope of the law, all but greensheet@greensheet.com.
the smallest businesses will need to comply. There are

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