As the CCPA’s effective date approaches, businesses are actively monitoring how companies will update their privacy notices to comply with the new disclosure requirements of the Act. While many companies are prepared to update their own privacy notices at the end of the year, policies that are preemptively changed before year-end are being reviewed and scrutinized by the industry for trends and signs of any industry standard practices surrounding such things as the disclosure of the “sale” of information or the collection of information by “enumerated category.”

In order to help companies understand and benchmark emerging industry practice, BCLP analyzed a random sample of the privacy notices of Fortune 500 companies and will continue to monitor each week how the sample-set evolves and changes as January 1, 2020 approaches and thereafter.1 The following summarizes the “state” of privacy notice revisions as of the week of December 2, 2019: