Microsoft announced this week that it would extend the consumer rights currently given to California consumers through the California Consumer Privacy Act to all consumers—no matter where they reside.

I applaud this move (especially because I don’t reside in CA). But why should my personal information be protected differently than those who live in California?

Many global companies are making the same choice, deciding to treat everyone’s personal information the same. It appears many states will follow California in affording similar privacy rights to consumers, and it sometimes is easier to implement the same policies and procedures for all consumers than for just those in specific states. And it does not appear that we will have a national privacy law any time soon. So what is a business to do?

For global companies, a one-size-fits-all solution makes sense from an efficiency and operational point of view. For others, baby steps make sense.

The point with CCPA compliance is that it is not one-size-fits-all. Each business needs to determine what makes sense for it in terms of risk and the cost and efficiency of operations. For some, it makes sense to extend the technological and compliance obligations to all consumers. But for others, the cost of doing so, as well as the number of people it affects, is prohibitive.

Businesses have to determine what makes sense for them for CCPA compliance.  They need to determine whether CCPA applies, how it applies, and how they will comply. It might make sense to implement a global compliance program or a baby step one. Either way, compliance is required by January 1, 2020, so now is the time to figure out which way to go.

Photo of Linn Foster Freedman Linn Foster Freedman

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chairs the firm’s Data Privacy and Security and Artificial Intelligence Teams. Linn focuses her…

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chairs the firm’s Data Privacy and Security and Artificial Intelligence Teams. Linn focuses her practice on compliance with all state and federal privacy and security laws and regulations. She counsels a range of public and private clients from industries such as construction, education, health care, insurance, manufacturing, real estate, utilities and critical infrastructure, marine and charitable organizations, on state and federal data privacy and security investigations, as well as emergency data breach response and mitigation. Linn is an Adjunct Professor of the Practice of Cybersecurity at Brown University and an Adjunct Professor of Law at Roger Williams University School of Law.  Prior to joining the firm, Linn served as assistant attorney general and deputy chief of the Civil Division of the Attorney General’s Office for the State of Rhode Island. She earned her J.D. from Loyola University School of Law and her B.A., with honors, in American Studies from Newcomb College of Tulane University. She is admitted to practice law in Massachusetts and Rhode Island. Read her full rc.com bio here.