The California Consumer Privacy Act has significant implications for Chief Marketing Officers. Here are some important principles CMOs should keep in mind when planning compliance efforts, included in my recent presentation to The CMO Club.

• Know what personal information you collect, and use, and share, and with whom.
• Know where that information came from.
• Yes, that means leads you bought, or were given, or scraped from the web.
• Yes, that also includes cookie information.
• Yes, that also includes custom audiences or adtech or targeted advertising.
• No, a banner that says “we have cookies, accept it” may not cut it for CCPA (and, actually, not for EU e-privacy either).
• Yes, CCPA has some silver lining regarding financial incentives for data use, but…
• No it is not clear-cut and requires some thinking and analysis of your loyalty programs.