Dec 23rd 2019

80% of Companies Have Not Updated Their Privacy Notices

The CCPA Is Only Two Weeks Away And 80% of Companies Have Not Updated Their Privacy Notices 

December 16, 2019: The CCPA’s effective date approaches, businesses are actively monitoring how companies are updating their privacy notices to comply with the new disclosure requirements of the Act.  While many companies are prepared to update their privacy notices at the end of the year, notices that are preemptively changed before year-end are being reviewed and scrutinized for trends and signs of any industry standard practices surrounding such things as the disclosure of the “sale” of information or the collection, and sharing, of information by “enumerated category.”

In order to help companies understand and benchmark industry practice, BCLP analyzed a random sample of the privacy notices of Fortune 500 companies.  As of December 13, 2019, 20% of the companies in the sample had released CCPA-revised privacy notices; 80% of companies had not updated their privacy notices. 

The net result is that, so far, updating privacy notices remains the exception and not the rule.  While the average “age” of current privacy notices (i.e., the time elapsed since a privacy notice was last updated) has shortened considerably in the past month, it still remains relatively high at 583 days since last update.

David A. Zetoony

Partner, BCLP Law