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.