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Survey of Fortune 500 Companies’ Privacy Representations

Bryan Cave Leighton Paisner LLP

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USA December 27 2019

There is no one strategy for disclosing privacy practices to consumers, or for complying with the federal and state laws – including the CCPA – that govern data privacy. The following summarizes current industry trends:

  • Privacy notices are, on average, over a year old.
  • The majority of companies have not updated their privacy notices for the CCPA.
  • Privacy notices that reference enumerated categories are evenly split between using tables and lists.
  • 10x more privacy notices disclose that they do not sell personal information than disclose that they do sell personal information.
  • The majority of privacy notices are silent or unclear about selling practices.
  • The vast majority of privacy notices do not include a “Do Not Sell” option.
  • Those companies that are disclosing the sale of information are complying with the CCPA’s requirement to provide a “Do Not Sell” option.
  • Only a small number of companies that don’t sell personal information are still providing a “Do Not Sell” option.
  • Most companies are not including a “Do Not Sell” link on their homepage.
  • Some companies include the “Do Not Sell” link, but it is non-functional.
  • Most companies offer access and deletion rights.
  • The average quantity of behavioral advertising cookies on a corporate homepage is 6.74
  • Most companies are not deploying a cookie notice or banner.
  • Those that do are split in terms of whether to use an opt-in, notice, or deemed consent banner.
Bryan Cave Leighton Paisner LLP - David Zetoony
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Filed under

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  • Internet & Social Media
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  • Bryan Cave Leighton Paisner LLP

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