Q: What aspects of the CCPA does Jornaya’s Privacy Guardian help with?
A: Privacy Guardian helps companies know if a site visitor is located in California and helps them prove what happened at each web event.
Knowing that a site visitor is located in California allows you to ensure that the proper disclosures are shown to that consumer. Since it can be difficult to know if an anonymous website visitor is a California resident, there are legal opinions that the Attorney General will likely deem IP geo as an acceptable proxy for California residents in providing the proper disclosures and rights. If your internal legal counsel has deemed IP geo as an acceptable proxy in their operations, the service we provide will help you access this data easily without new technical integration and without needing to contract with another third party.
If you are dealing with a CCPA lawsuit, proving what happened at each event will be beneficial in your defense. One key value proposition is that by taking the step of deploying a third party like Jornaya on your sites, you are taking precautions to ensure privacy is being honored across your operations. Second, for each individual consumer, you will be able to demonstrate that the proper notifications were shown to the consumer and were visible by the consumer and that the consumer did not opt-out of their data being collected or shared. In addition, there are some key exemptions in the regulation, one of which is that companies do not need to delete consumer data if the data they captured was because they were providing a good or service requested by the consumer. By demonstrating that a consumer completed a lead form in which they clearly expressed their desire to be connected to service providers, those businesses involved will be able to substantiate their right to this exemption.
Q: How does the solution differ from TCPA Guardian?
A: 1P Privacy Guardian helps you honor the privacy of your website visitors through compliance with privacy regulations. The initial Guardian product was focused on helping you stay compliant with the TCPA (formerly known as 1st party TCPA Guardian), and it is now being expanded to help you stay compliant with the CCPA effective January 1, 2020. Jornaya will continue to enhance the newly named 1P Privacy Guardian to support more privacy regulations.
The specific product features that will be available on January 1, 2020 include the ability to leverage a Compliance Report and a Visual Playback for CCPA complaints, as well as the ability to have real-time data informing you of the location of your site visitors based on their IP address.
Q: How do customers request proof of event for CCPA issues?
A: The request process for proof of event is the same as it is currently for TCPA Guardian. Customers complete a request in the Jornaya services portal, you will be asked to specify whether the report and VP request is for TCPA or CCPA purposes.