Auto dealers, are you ready for 2020? The dawn of the new decade, just a few short months away, heralds a flood of new laws and regulatory changes. And, as usual, California appears to be ahead of the curve.
On January 1st of next year, the California Consumer Privacy Act will go into effect. The CCPA gives consumers new rights over their personal data. In California, auto buyers will soon be allowed to request what information dealers have about them along with how that information was collected, how it’s been used, and who it’s been shared with. Dealers must be able to promptly disclose or delete this information per each customer’s request.
Not sure whether your dealership is ready? Have no fear—AutoSuccess magazine recently published an overview of the CCPA, featuring details about the law and its exceptions, along with practical guidance for compliance.
Attorneys Erin Tenner, Richard Williams, and Nathan Lee (of California-based firm Gray Duffy) suggest dealers take the following steps now:
1. Update privacy policies to inform consumers of their rights to delete their data as well as what categories of personal information your dealership collects.
2. Develop a procedure for deleting private information when a customer requests a deletion.
3. Appoint an employee to be in charge of customers’ personal information and make sure that individual can verify the identity of any consumer who files a request.
4. Keep in contact with any vendors or third-parties who you share customer information with, and make sure their addresses are up-to-date.
5. If you sell customer data, familiarize yourself with the additional requirements for businesses that sell consumers’ private information.
6. Create a smart deletion process that allows you to determine if and when to erase all of a customer’s data versus certain pieces of information.
7. If you choose not to delete all of customer’s data after receiving a request, develop a customer appeal process.
8. Talk to your attorney as soon as you can after receiving any notice of violation.