Comments to the final California Consumer Privacy Act regulations asked how franchisor/franchisee compliance with CCPA works?

  • Does CCPA apply to the franchisee for collecting data on behalf of the franchisor?
  • How is the franchisor supposed to calculate its revenues for the purpose of the $25 million applicability threshold?
The California Attorney General Responded:
  •  The regulation provides general guidance for CCPA compliance.
  • Further analysis is necessary before proposing a regulation that provides guidance specific to the franchisor/franchisee relationship and the statutory definition of “business” in CCPA.

CCPA Final Regs Franchise Odia Kagan