Companies Must Ensure CCPA Privacy Notices Comply with Disability Accessibility Requirements – Duane Morris
Disability accessibility, including specific accessibility requirements for websites, are an independent feature of the final regulations for the California Consumer Privacy Act (CCPA), submitted on June 1, 2020, by the Office of the California Attorney General to the California Office of Administrative Law (OAL). These accessibility requirements supplement existing requirements under federal and state laws already in effect. Businesses will need to be proactive and flexible with compliance with these laws and regulations.
The OAL has 30 working days, plus an additional 60 calendar days under an executive order related to the COVID-19 pandemic, to review the final regulations package. Once approved by the OAL, the final regulation text will be filed with the Secretary of State and become enforceable by law.
Accessibility Requirements
The final regulations require the following required disclosures be “reasonably accessible” to consumers with disabilities:
- Privacy policy of online and offline practices regarding the collection, use, disclosure and sale of personal information and of the rights of consumers regarding their personal information.
- Notice at collection explaining the categories of information to be collected and the purposes for which it will be used;
- Notice of right to opt out explaining a consumer’s ability to direct a business to stop selling personal information; and
- Notice of financial incentive explaining the financial incentive or price or service difference the business may offer.