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The Enforcement Division of the California Privacy Protection Agency entered into a Stipulated Judgment with the Tractor Supply Company.  The underlying litigation involved alleged violations of the California Privacy Protection Act.  In the Judgment, the parties agreed that:

  • TSC failed to properly implement opt-out mechanisms for sale/sharing of personal information.
  • TSC had an ineffective ‘Do Not Sell My Personal Information’ webform that didn’t stop third-party tracking.
  • TSC failed to process opt-out preference signals.
  • TSC had inadequate contracts with service providers and third parties.
  • TSC had deficient privacy policy lacking required CCPA disclosures.
  • TSC had insufficient notice to job applicants about their CCPA rights.

To settle the dispute, TSC agreed to pay a fine in the amount of $1,350,000.  Additionally, TSC agreed to the following:

  • Maintain inventory of tracking technologies and properly configure systems to honor opt-out requests.
  • Ensure symmetry of choice in tracking technology interfaces.
  • Review and update privacy policies.
  • Notify employees and job applicants of updated policies.
  • Train personnel handling CCPA requests.
  • Modify contract management processes.
  • Post required metrics annually for five years.
  • Provide annual certification of compliance for four years.
  • Implement monitoring program for opt-out requests.

ECAC seeks to provide members with up to date information regarding consumer privacy actions.  Please contact ECAC with any questions  your organization may have.

See the Final Order here.

Mitchell Roth

mroth@rothjackson.com

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