In order to help businesses understand and benchmark industry practice, Greenberg Traurig attorneys analyzed the publicly available privacy policies of companies within the Fortune 500. As of October 2022 – nearly two years after the CCPA took effect – 71% of companies had updated their privacy policies to account for the CCPA. It is not clear whether the rate at which Fortune 500 companies updated their privacy policies is representative of the rate at which small, emerging, or mid-sized companies updated their privacy policies. As many smaller companies may not meet the de minimis threshold for complying with the CCPA, it is possible that fewer small companies have updated their privacy policies for the CCPA.
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