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California Consumer Privacy Act Enforcement Series: The Infamous “Do-Not-Sell” Button

Cybersecurity_914054068
By Ronald I. Raether, Jr., Ashley L. Taylor, Jr., Sharon Klein, Oscar Figueroa, Lauren Geiser, Sadia Mirza, Alex Nisenbaum, Wynter Deagle, Anne-Marie Dao & Yarazel Mejorado
July 14, 2020
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Enforcement of the California Consumer Privacy Act (CCPA) began July 1, 2020. Our privacy team at Troutman Pepper includes several attorneys who worked in an attorney general’s office. This privacy regulatory team has identified six areas of enforcement likely to catch the California Office of the Attorney General’s (OAG) attention, which arguably holds sole regulatory enforcement authority under the Act. This six-part series will focus on those areas of the law. Building on the experience of advising clients on the CCPA since its passage, our privacy compliance team will then discuss discrete strategies to minimize enforcement risk and bolster compliance efforts.

Below is the tentative schedule for this six-part series. This week’s alert focuses on the infamous “Do-Not-Sell” button and can be accessed here.

  • NEW: Enforcement Area No. 1: The Infamous “Do-Not-Sell” Button.
    Available: here
  • Enforcement Area No. 2: Treating the CCPA Like a Check-the-Box Exercise.
    Release Date: July 20, 2020
  • Enforcement Area No. 3: Service Providers.
    Release Date: July 27, 2020
  • Enforcement Area No. 4: Businesses Collecting Children’s Personal Information and Health Related Data.
    Release Date: August 3, 2020
  • Enforcement Area No. 5: Failing to Provide Adequate Notice at Collection.
    Release Date: August 10, 2020
  • Enforcement Area No. 6: OAG’s Reaction to CPRA Referendum.
    Release Date: August 17, 2020
  • Complimentary Webinar: Strategies to Prepare for Six Potential Target Areas of CCPA Enforcement by the CA Attorney General.
    August 19, 2020 2 p.m. EST
    Register here
Photo of Ronald I. Raether, Jr. Ronald I. Raether, Jr.

Ron understands technology and specializes in responding to data integrity events (breach response) and advising companies on maximizing data use through multiple regulatory environments.

Read more about Ronald I. Raether, Jr.Email Ronald I.'s Linkedin Profile
Photo of Ashley L. Taylor, Jr. Ashley L. Taylor, Jr.

Ashley specializes in regulatory and enforcement matters involving the state Attorneys General, CFPB and FTC.

Read more about Ashley L. Taylor, Jr.Email Ashley L.'s Linkedin Profile
Photo of Sharon Klein Sharon Klein

Sharon helps businesses succeed in technology matters, from crafting strategies for protecting data privacy and security to structuring IT and outsourcing transactions.

Read more about Sharon KleinEmail
Photo of Oscar Figueroa Oscar Figueroa

Oscar is a litigator focusing his practice on intellectual property and business litigation matters. Oscar has litigation experience in California State Court and Federal Courts throughout the country.

Read more about Oscar FigueroaEmail
Photo of Lauren Geiser Lauren Geiser

Lauren is an associate in Troutman Sanders’ Business Litigation Group and the Government Investigations, Compliance, and Enforcement Section. Lauren’s practice focuses on representing clients involved in regulatory, civil, and criminal investigations and litigation. Lauren also represents clients interacting with and being investigated by…

Lauren is an associate in Troutman Sanders’ Business Litigation Group and the Government Investigations, Compliance, and Enforcement Section. Lauren’s practice focuses on representing clients involved in regulatory, civil, and criminal investigations and litigation. Lauren also represents clients interacting with and being investigated by state Attorneys General.

Read more about Lauren GeiserEmail
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Photo of Sadia Mirza Sadia Mirza

Sadia is a Certified Information Privacy Professional in the United States (CIPP/US) and a Certified Information Privacy Manager (CIPM). She works with clients on a wide array of data protection and privacy matters, including the recently enacted California Consumer Privacy Act, and also…

Sadia is a Certified Information Privacy Professional in the United States (CIPP/US) and a Certified Information Privacy Manager (CIPM). She works with clients on a wide array of data protection and privacy matters, including the recently enacted California Consumer Privacy Act, and also specializes in incident response having handled a number of data breaches and investigations in a variety of industries.

Read more about Sadia MirzaEmail Sadia's Linkedin Profile
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Photo of Alex Nisenbaum Alex Nisenbaum

Alex is a trusted advisor to companies in all industry sectors regarding data privacy and security, and information technology transactions.

Read more about Alex NisenbaumEmail
Photo of Wynter Deagle Wynter Deagle

Wynter Deagle combines her passion for emerging technology and her talent for strategy to create efficient, value-driven and business-centered results in litigation and privacy matters. Wynter’s sharp analysis, practicality and tactical approach make her a true business partner and fierce advocate.

Read more about Wynter DeagleEmail
Photo of Anne-Marie Dao Anne-Marie Dao

Anne-Marie Dao is a zealous advocate for her clients.  Her client-driven approach allows her to achieve results tailored to the needs of each specific client, in everything ranging from negotiating early settlements to bet-the-company litigation for her clients.

Read more about Anne-Marie DaoEmail
Photo of Yarazel Mejorado Yarazel Mejorado
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  • Posted in:
    Financial
  • Blog:
    Consumer Financial Services Law Monitor
  • Organization:
    Troutman Pepper Hamilton Sanders LLP
  • Article: View Original Source

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