CCPA Information

The proposed regulations are intended to operationalize the CCPA and provide practical guidance to consumers and businesses subject to the law. The regulations would address some of the open issues raised by the CCPA and would be subject to enforcement by the Department of Justice with remedies provided under the law. The proposed regulations were drafted after a broad and inclusive preliminary rulemaking process, which included seven public forums held throughout the state and a public comment period during which the office received over 300 written comments.

Aspect achieved a strong compliance position regarding the EU’s General Data Protection Regulation (GDPR) and those compliance efforts are being leveraged for CCPA preparation. We completed the exercise of data mapping of personal information processes and locations of storage, along with processes to respond to access requests from consumers. We are reviewing our data access request procedures, privacy policies, and websites to identity and remedy gaps with CCPA requirements. Aspect’s current knowledge and records regarding data collection, storage, breach response, data subject access requests, and retention allow Aspect to address these risks as the CCPA develops.

CCPA may have a limited applicability to Aspect when compared with GDPR. For example, the law applies mainly to personal information that is controlled by Aspect. However, we anticipate that more states will adopt similar laws and our preparation will keep that perspective in mind.

We recognize that our customers and partners may require Aspect’s assistance to comply with CCPA and we stand ready to assist. For example, a customer may receive a request for data access from a California resident and our support team will be prepared to advise on product capabilities and functionalities to carry out the request.

The Attorney General closed public comment on the implementing regulations on December 6, 2019, and is now considering modifications. During this process Aspect will closely monitor the results and continue to assess legal obligations, security risks, problematic practices, and pinpoint operational priorities.

Aspect is also reexamining data processing policies, data access request procedures, data breach protocols, access and deletion procedures, privacy notices, data retention policies, product manuals, including scenarios involving the improper or unauthorized collection, use, or sharing of personal information as defined under CCPA.

For reasons above, Aspect will maintain a fluid approach in its preparation for CCPA. Our customers and partners will benefit from our early compliance efforts and we will closely monitor and take all necessary actions prior to enforcement.