What are the requirements for California Consumer Privacy Act (CCPA) training? At Section 1798.135(a)(3), the CCPA requires that businesses “ensure that all individuals responsible for handling consumer inquiries about the business’s privacy practices or the business’s compliance with this title are informed of all requirements in Section 1798.120 and this section and how to direct consumers to exercise their rights under those sections.”
The CCPA’s training requirements specifically mention that all employees responsible for handling consumer inquiries about privacy practices must be informed of the requirements of 1798.120 and 1798.135, which primarily focus on the sale of consumer personal information.
Section 1798.120 includes:
- the consumer’s right to opt out of the sale of personal information to third parties
- consumers’ rights to be notified that they have a right to opt out, and
- the opt in rights for children
Section 1798.135 includes:
- requirement to have a link on the homepage titled “Do Not Sell My Personal Information”
- requirement to have a description of consumer rights
The statute says little else about CCPA training requirements, and thus it isn’t clear what training, if any, is needed for other rights and obligations under the CCPA.
To satisfy the CCPA’s training requirements, I recommend CCPA-specific training for employees involved in handling consumer inquires or designing the mechanisms for consumers to exercise their rights. CCPA training will also be useful for employees negotiating vendor agreements. I also recommend a brief mention of some of the unique CCPA rights and responsibilities for all employees as part of a general privacy awareness course.
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This post was authored by Professor Daniel J. Solove, who through TeachPrivacy develops computer-based privacy and data security training. He also posts at his blog at LinkedIn, which has more than 1 million followers.
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