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Education

that data. The administrative consent language and will create costs on the part of businesses obligated to
burden of handling consumer cater to consumer rights under the act.
data-deletion requests could
also be massive. I do not expect the act to significantly impact ISOs.
• Mandated opt-in before sale
of information pertaining to In publishing The Green Sheet, neither the author nor the publisher is engaged in rendering legal,
children under age of 16: This accounting or other professional services. If legal advice or other expert assistance is required,
is important to protect infor- the services of a competent professional should be sought. For further information on this article,
mation concerning minors, please contact Adam Atlas, Attorney at Law via email at atlas@adamatlas.com or by phone at
which constitutes a substan- 514-842-0886.
tial amount of data, given that
children are, ever more, "cloud-
based."
• Right to know the categories
of third parties with whom
your data is shared: The value
of this lies in the fact that most
of us do not know how our in-
formation is being shared. Re-
cently, I was at a bank branch
helping my son open his first
bank account. I was using the
bank's Wi-Fi. While connected
to the Wi-Fi and opening the
account, I received an SMS ad-
vertisement promoting a back-
to-school cell phone plan.
With my knowledge of Wi-Fi
providers' data collection prac-
tices, I am all but certain the
data collected on me in that
short moment was enough to
connect the dots between my-
self, my son, the account and
our phone plans. If we were in
California in 2020, we might
have known that in advance –
and even had the right to opt
out.
ISO take-aways

If you are an ISO, and you sign up
merchants for a large national pro-
cessor with annual gross revenues
of over $25 million, that processor
is subject to the act and may turn to
you for help with compliance.

It's hard to predict how processors
and banks will become compliant
with the law, but it will most likely
be dealt with through additional
disclosure by banks, processors and
merchants. If the very stringent EU
GDPR law is any indicator, compli-
ance will not bring business to a halt
in California. Instead, it will give
work to lawyers who write privacy
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