CIPP-US · Question #88
SCENARIO Please use the following to answer the next question: Otto is preparing a report to his Board of Directors at Filtration Station, where he is responsible for the privacy program. Filtration…
The correct answer is C. That business contact information could be considered personal information governed by CCPA. The CCPA applies to any business that collects personal information of California residents, regardless of where the business is located. The CCPA defines personal information broadly as any information that identifies, relates to, describes, is reasonably capable of being…
Question
SCENARIO Please use the following to answer the next question:
Otto is preparing a report to his Board of Directors at Filtration Station, where he is responsible for the privacy program. Filtration Station is a U.S. company that sells filters and tubing products to pharmaceutical companies for research use. The company is based in Seattle, Washington, with offices throughout the U.S. and Asia. It sells to business customers across both the U.S. and the Asia-Pacific region. Filtration Station participates in the Cross-Border Privacy Rules system of the APEC Privacy Framework. Unfortunately, Filtration Station suffered a data breach in the previous quarter. An unknown third party was able to gain access to Filtration Station's network and was able to steal data relating to employees in the company's Human Resources database, which is hosted by a third-party cloud provider based in the B. S. The HR data is encrypted. Filtration Station also uses the third-party cloud provider to host its business marketing contact database. The marketing database was not affected by the data breach. It appears that the data breach was caused when a system administrator at the cloud provider stored the encryption keys with the data itself. The Board has asked Otto to provide information about the data breach and how updates on new developments in privacy laws and regulations apply to Filtration Station. They are particularly concerned about staying up to date on the various U.S. state laws and regulations that have been in the news, especially the California Consumer Privacy Act (CCPA) and breach notification requirements. The Board has asked Otto whether the company will need to comply with the new California Consumer Privacy Law (CCPA). What should Otto tell the Board?
Options
- AThat CCPA will apply to the company only after the California Attorney General determines that it
- BThat the company is governed by CCPA, but does not need to take any additional steps because
- CThat business contact information could be considered personal information governed by CCPA.
- DThat CCPA only applies to companies based in California, which exempts the company from
How the community answered
(39 responses)- A15% (6)
- B5% (2)
- C72% (28)
- D8% (3)
Explanation
The CCPA applies to any business that collects personal information of California residents, regardless of where the business is located. The CCPA defines personal information broadly as any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This could include business contact information, such as name, email address, phone number, or job title, if it is linked to a specific individual. Therefore, Otto should tell the Board that business contact information could be considered personal information governed by CCPA, and that the company may need to comply with the CCPA requirements, such as providing notice, honoring consumer rights requests, and implementing reasonable security measures.
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