The California Consumer Privacy Act gives California residents the right to know what personal information a business collects about them and how it is used. The law likewise imposes obligations on businesses to ensure consumers can exercise this right. Although the CCPA and its regulations provide a framework, operationalizing the consumer request process can be complex.

Two compliance issues that present challenges for organizations covered by the CCPA are:

• The scope of information subject to disclosure.
• The use of third parties to submit consumer requests.

The landscape regarding these topics continues to change. Recent developments include:

• Inferences subject to disclosure: the California attorney general’s opinion regarding internally generated inferences and the scope of the disclosure obligation.
• Employee information will be subject to requests to know: the CCPA employee exemption set to expire Jan. 1, 2023.
• Use of authorized agents: the advocacy work being done by Consumer Reports regarding the use of authorized agents.

Framework for CCPA requests to know

Similar to the EU General Data Protection Regulation Article 15, the CCPA gives consumers (defined as a natural person who is a California resident) the right to request that businesses disclose the personal information collected about the consumer. Section 1798.110(a) specifies a consumer is entitled to request the disclosure of:

• The categories of personal information the business has collected about the...

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