The CCPA only provides enhanced rights and protections for consumers who are California residents. As a result, businesses with national or global customer bases must decide whether to extend the CCPA’s consumer rights and disclosure requirements to their entire customer base, including both California and Non-California residents—Or should they provide CCPA rights to only consumers residing in California—and develop separate privacy practices for non-California resident consumers? Before making this decision, businesses should consider several practical implications, including:
- Can your business effectively distinguish between information relating to California residents and information relating to non-California residents?
- Will your organization be able to differentiate whether each customer and website visitor qualifies as a California resident?
- What if a customer subsequently moves and changes their residency status? Are your systems prepared to handle such changes?
- Will customer relations be impacted by telling non-California consumers that they are entitled to fewer privacy rights than California consumers?
Businesses must carefully decide how they will answer these questions. Forward-thinking organizations are ones designing their compliance strategies toward achieving consumer trust and loyalty. This means spending time designing privacy policies that match their brand of trust rather than ones bestowing rights on only one segment of their customer base.