Now that we understand who has CCPA rights and what personal information means, let’s examine what you need to tell consumers about your use of their personal information and how to present that disclosure.
The CCPA requires businesses to notify consumers about privacy at or before the point at which the business collects information. This could mean signage outside of a brick and mortar store where you’re using video surveillance, or a website banner that informs visitors about online information collection. Provide your notices in every language in which you ordinarily transact with or advertise to consumers.
To comply with point of collection requirements, companies are expanding their ubiquitous cookie banners to refer more generally to information collection, use and disclosure.
Here’s an example of best practices from a convenience store chain, with a banner that combines disclosure about cookies and information collection and sharing. As you see here, a notice can consist of a brief summary and a link to a full privacy policy explaining what information a business collects and why. Businesses that quote unquote “sell” personal information also need a “Do Not Sell My Info” link in their homepage footer that leads to a means for consumers to opt out of personal information sales. You can see that behind the banner, this convenience store has also included a Do Not Sell Link in their homepage footer.