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#2228079 - 12/30/19 07:00 PM Re: NEW California Privacy Law Reg Warrior
Reg Warrior Offline
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Joined: Jan 2017
Posts: 185
Business/Commercial accounts/loans have a one year exemption from CCPA. We have asked our attorney the same questions, and was advised to wait to see the final regulations from the CA attorney general and if any additional changes are made by the Legislature during 2020.

Also beware, that the organization behind CCPA, does not think that the current version of CCPA goes far enough and is trying to get an initiative on the fall ballot. https://www.caprivacy.org/

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#2230697 - 02/11/20 04:22 PM Re: NEW California Privacy Law Reg Warrior
Reads Regs Offline
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Joined: Nov 2004
Posts: 2,282
Link to redlined version of latest CA privacy proposed regulation.

https://oag.ca.gov/sites/all/files/agweb/pdfs/privacy/ccpa-text-of-mod-redline-020720.pdf?
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

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#2230736 - 02/11/20 07:22 PM Re: NEW California Privacy Law Reg Warrior
Reg Warrior Offline
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Joined: Jan 2017
Posts: 185
Comments on the modified proposed regulations are due the CA Attorney General by Feb. 25 at 5pm.

https://oag.ca.gov/privacy/ccpa

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#2244444 - 10/21/20 10:05 PM Re: NEW California Privacy Law Reg Warrior
green_banker Offline
New Poster
Joined: Oct 2020
Posts: 1
Now that this is effective, has anyone determined what PI if any is exempted under GLBA? If you receive a copy request, what are you giving them?

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#2244469 - 10/22/20 03:38 PM Re: NEW California Privacy Law Reg Warrior
Reg Warrior Offline
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Joined: Jan 2017
Posts: 185
Based on the GLBA and California Financial Information Privacy Act, all PI we collect on members (we are a credit union) is exempt from CCPA. However any PI we collect on consumers associated with business account/commercial loans is not exempt from CCPA, nor is our own employee PI. If a member submits a request, we advise them that their PI is exempt from CCPA and that we comply with federal and state privacy laws.

FYI there is ballot measure that could make all this much more fun.
https://voterguide.sos.ca.gov/propositions/24/
https://vig.cdn.sos.ca.gov/2020/general/pdf/topl-prop24.pdf

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#2245547 - 11/16/20 03:55 PM Re: NEW California Privacy Law Reg Warrior
awilli Offline
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Joined: Oct 2014
Posts: 263
What is the delivery timing requirement for the CA Privacy Notice?

ex. Within three days after application? At the time of application (prior to application)? Before applicant information is collected? Etc...
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#2245552 - 11/16/20 04:30 PM Re: NEW California Privacy Law Reg Warrior
Reg Warrior Offline
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Joined: Jan 2017
Posts: 185
The Notice at Collections must given prior to any personal information is collected from a consumer.

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#2245556 - 11/16/20 05:27 PM Re: NEW California Privacy Law Reg Warrior
awilli Offline
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Joined: Oct 2014
Posts: 263
So before they even apply for a loan application? (since there are certain information needed for an application)
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Say what you mean, mean what you say, but don't say it mean.

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#2245559 - 11/16/20 05:57 PM Re: NEW California Privacy Law Reg Warrior
Reg Warrior Offline
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Joined: Jan 2017
Posts: 185
Yes. Keep in mind, personal information collected for opening, maintaining, or servicing a personal account/loan is exempt as this personal information falls under GLBA or CalFIPA. Personal information that is collected for employment, business banking, commercial lending, marketing and other areas is not exempt from CCPA.

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#2245563 - 11/16/20 06:57 PM Re: NEW California Privacy Law Reg Warrior
Inherent_Risk Offline
Gold Star
Joined: Jan 2017
Posts: 307
Am I right that business to business and employment exemptions were extended to 2023 by the new ballot initiative?

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#2245565 - 11/16/20 08:00 PM Re: NEW California Privacy Law Reg Warrior
Reg Warrior Offline
100 Club
Joined: Jan 2017
Posts: 185
Yes, but you still need to provide the Notice at Collection beginning no later than 1/1/2022, due to the look back period for responding to requests that begins 1/1/2023. We've had our Notices posted since July for employment and business, and all marketing related items have had a form of the Notice since January.

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