Commenters on the final California Consumer Privacy Act (CCPA) regulations asked what happens if you map your third party sharing and implement a process but still inadvertently sell personal information as such term is defined in CCPA?

The California Attorney General responded: This is not an exception to the definition of sale but if you really have a process, and implement it and follow it, the Office of Attorney General may exercise prosecutorial discretion and not enforce.

CCPA Final Regs Inadvertent Sale Odia Kagan