CCPA Complimentary Assessment
There were 2 significant CCPA developments in the Summer of 2020 that small-dollar lenders may have missed. This is a significant event, as the CCPA changes have specificity that did not previously exist. These are indicators that the AG is taking enforcement action seriously. Small-dollar lenders operating in California need to pay attention.
CyberSecurityBase is performing a complimentary CCPA Regulatory Action Exposure Assessment for select companies.
The purpose of the assessment is to report to the Chief Compliance Officer/General Counsel if the customer-facing website may be exposing the company to regulatory action.
There were 2 significant CCPA developments this summer that we are noticing that small-dollar lenders may have missed:
- On 6/1/2020, the California AG published proposed changes to the CCPA (29 pgs of clarifications to the requirements passed in 2019)
- On 8/14/2020, the majority of the changes were formally approved
This is a significant event, as the approved changes have specificity that did not exist under the previous version of the regulation. We see these as indicators that the AG is taking enforcement action seriously.
This is a limited time offer in an effort to provide you with valuable information, serve as a resource, and create an opportunity to earn your business.
SIGN UP FOR THE FREE CCPA ASSESSMENT
Who is this for?
You are invited to request a complimentary assessment. Companies with the following demographics are the best fit:
- Small-dollar lender operating primarily online
- Serve consumers in the State of California
- Prioritized CCPA compliance efforts in 2019 and would benefit from an outside review of the customer-facing website before the next state examination
Should your company not meet all company demographics, please submit the assessment request. A member of our team will review the request and confirm if we can accommodate your request.
What else do I need to know?
This information is valuable for companies that need to demonstrate compliance to the CCPA. All assessment items are public-facing. This means that areas of non-compliance may expose your company to regulatory action, as these open the door to CCPA inquiries from “privacy-minded” consumers and/or California regulators.
This is an especially significant event for small-dollar online lenders, as lenders rely heavily on receiving and analyzing consumer data from CRAs, data vendors, and lead providers. The CCPA places this data sharing infrastructure under a new level of scrutiny, requiring prompt collaboration across the small-dollar lending industry.
SIGN UP FOR THE FREE CCPA ASSESSMENT
What does this include?
- Assessment of your company website for key items required under the approved CCPA changes
- A written report, summarizing the assessed areas, assessment outcomes, and supporting screenshots
- An offer for a 45-min consultation call to review the assessment outcomes and how the CyberSecurityBase team can be a resource
Consider taking action now, before a bank partner, state regulator, or other stakeholder inquires about your CCPA Compliance Program.
The Breadth of CCPA
There are various components to the CCPA. CyberSecurityBase has broken the CCPA into 8 components. Some companies will need to fulfill all components, while others will only need to fulfill some. This all depends on the type of data your company holds, the source of this data, and how the data is used by the company.
Please note that this complimentary assessment is not a comprehensive CCPA compliance review or audit. CyberSecurityBase is a data security and privacy consultancy, not Legal Counsel. For clarity, the information in this report is not Legal advice.
Disclosures
Record-Keeping
3rd-Party Vendor Management
Change Management
Verifiable Consumer Requests
Data Sell Opt-Outs
Reasonable Security Measures
Training
*Covered By Complimentary Assessment
*Not Covered By Complimentary Assessment
Available CCPA Professional Services from CyberSecurityBase
CyberSecurityBase provides the following professional services to small-dollar lenders needing CCPA compliance assurance support:
- CCPA Implementation Audit
- CCPA Impact Assessment
- CMS Monitoring and Testing Program Update