“A.B. 846 (Burke) would increase the power of businesses to force consumers to pay for their CCPA privacy rights.” Have AdTech’s considered the potential ramifications of this?
- Charging an Opt-Out processing fee may expose a company to extra Culpability. If that customer’s data re-appears in your data eco-system from any of the following sources what additional liability will you incur?
- Ingestion from IoT.
- Ingestion from Third Party Data Assets through purchase or acquisition.
- New activity from a customer that you fail to recognize as an Opt-Out customer
- Recovery of data from backup sources?
- Merging of Legacy, Big Data, or Data Warehousing assets.
- Accidental decryption of data from emails or other Office documents.
The amount of effort to properly and continually identify and remove data from Opt-Outs, may take more effort than you think.
The fine of being unable to comply with a request may be up to $750. What might the jury award knowing those Consumers paid to have their data removed and you couldn’t deliver? What if it can also be shown that you knew you couldn’t deliver?
#CCPA #GDPR #Big Data #Data Compliance #PII #Facebook #Hadoop #AWS #Spark #IoT #California