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