CCPA Compliance Reminder: Annual Update Requirement for Online Privacy Policies
For businesses subject to the California Consumer Privacy Act (CCPA), a compliance step often overlooked is the requirement to annually update the businesses online privacy policy. Under Cal. Civ. Code § 1798.130(a)(5), CCPA-covered businesses must among other things update their online privacy policies at least once every 12 months . Note that CCPA regulations establish content requirements for online privacy policies, one of which is that the policy must include “the date the privacy policy was last updated.” See 11 CCR § 7011(e)(4). As businesses continue to grow, evolve, adopt new technologies, or otherwise make online and offline changes in their business, practices, and/or operations, CCPA required privacy policies may no longer accurately or completely reflect the collection and processing of personal information. Consider, for example, the adoption of emerging technologies, such as so-called “artificial intelligence” tools. These tools may be collecting, inferring, or pro...