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Toll free phone numbers and the CCPA (Update)

Mathieu

Mathieu

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Update 11/01/2019

AB 1564 will do away with the toll-free number requirement if these businesses provide both an email and mailing address. However, in the instance where these businesses operate exclusively online, they are not required to provide a mailing address or a toll-free number, so long as they maintain a website that allows consumers to request their personal information. Complianz will be updated accordingly.

Orginal article

In January 2020 the CCPA comes into force. The Californian legislation is quite similar to the GDPR, which came into force in Europe on May 2018.

There are several differences between the CCPA and the GDPR. In this article, we discuss toll-free phone numbers. An aspect that is mandatory within the CCPA, from January 2020 on.

Toll-Free Phone Numbers

The CCPA requires companies to set up specific communication channels so that California residents can always request information about their data.

The CCPA states that you are obliged to comply with the following:

“Make available to consumers two or more designated methods for submitting requests for information required to be disclosed according to Sections 1798.110 and 1798.115, including, at a minimum, a toll-free telephone number, and if the business maintains an Internet Web site, a Web site address.”

A toll-free telephone number is, therefore, a minimum requirement for the CCPA. And also a requirement for anyone who processes personal data of California residents!

Anonymizing IP addresses in an analytical tool such as Google Analytics is not enough to get out of this. There is always the chance that someone from California will fill in the contact form. Personal data of a California Consumer will then still be processed.

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