A business that is subject to the CCPA will need to update its consumer-facing online privacy policy. At a bare minimum, a privacy policy (and any California-specific privacy disclosure) must disclose:

• A description of a consumer’s right to disclosure regarding the personal information (“PI”) that the business has collected about the consumer, a consumer’s right to disclosure regarding the business’s sale of her or his PI, and a consumer’s right not to be discriminated against for exercising any rights under the CCPA [Cal. Civ. Code §1798.130(a)(5)(A)];
• Categories of PI collected, sold, or disclosed in the preceding 12 months [Cal. Civ. Code §1798.130(a)(5)(B)&(C)]; and
• Two or more designated methods for submitting consumer requests, including a toll-free number and a website address [Cal. Civ. Code §1798.130(a)(1)].

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