The California Consumer Privacy Act of 2018 (“CCPA”) will become law on January 1, 2020, and Finastra is committed to helping our customers stay informed and in compliance with its requirements. The CCPA provides California residents with new rights regarding the collection, use and sale of their personal information, and these new rights ultimately drive new requirements on financial institutions and their service providers doing business with California residents.
The language of the CCPA itself is broad and in many areas remains unclear so it is widely expected that rulemaking by the California Attorney General will provide the necessary detail around how financial institutions and their service providers should implement it. To date, the California Attorney General has completed several town-halls to collect feedback on implementing regulations, and it is required to issue those regulations no later than July 1, 2020.
Finastra has been and continues to monitor development around the CCPA and the various proposed amendments from the California legislature, as well as the ongoing rulemaking process by the California Attorney General. Additionally, we are conducting internal data inventories, coordinating with our California state legal counsel, and developing product strategies on how Finastra will assist your institution in complying with the CCPA. Please note however, that the details of any product changes will likely not be released until after the California Attorney General releases implementing regulations clarifying the ambiguities in the law.
In the interim, we will be publishing summary articles to assist your institution in understanding the changes in the CCPA, the risks and effective date of the CCPA, discussing the important partial exemption for financial institutions collecting data under the Gramm-Leach Bliley Act, and examining some of the larger unknown areas of the CCPA as it stands today. Look for these articles to begin being published starting in July 2019 through our Fusion Compliance Management solution.
Fusion Servicing Director will provide updates on our plans to make changes relating to the CCPA, if any, via this product bulletin format, so we suggest you subscribe to it in order to receive the latest updates as they are published. Our current assessment of items for you to be aware of is covered below. If you have questions in the interim, please contact Eric Nelson.
This Product Bulletin is posted to make you aware of the issue it describes so you can determine the steps or changes necessary to mitigate or avoid risk, ensure document compliance, or otherwise address the issue. This bulletin does not constitute legal advice. Any legal questions that your financial institution has should be directed to your compliance officer and legal counsel.
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