Published: June 2019Click To View (PDF)

Companies find the California Consumer Privacy Act much more prescriptive than most other privacy laws. It contains a multitude of definitions, defined terms, and technical drafting errors and ambiguities, and the state legislature is considering numerous amendments. One term that is used multiple times in the statute and not defined in the current version of the CCPA or any of the amendment bills is the term “account.”

This white paper, authored by Baker & McKenzie Partner Lothar Determann and IAPP Westin Fellow Mitchell Noordyke, CIPP/E, CIPP/US, CIPM, outlines how businesses must develop a perspective on the definition of account as they work to operationalize their CCPA compliance programs with respect to data access requests.