California Consumer Privacy Act of 2018 (CCPA)

The California Consumer Privacy Act of 2018 (CCPA) is the most extensive consumer privacy legislation passed in the United States to date. The CCPA will go into effect on January 1, 2020 and enforcement will being on July 1, 2020.

The CCPA provides consumer privacy rights for California residents and imposes rules on businesses that handle the personal information of California residents.  The CCPA focuses on transparency – providing both the right to know about the collection and use of their personal data and the right to opt-out under certain circumstances of the use of that personal data.

The CCPA covers consumers — broadly defined as California residents currently in the state and those traveling outside of the state – by providing California residents the right to access, delete, and opt-out of the use of their personal data. The personal data protected under the CCPA is data that directly or indirectly, identifies, describes, or can reasonably be linked to a particular consumer or household.

We want to be very clear: we do not sell your personal information.

However, we are committed to protecting your privacy and have made updates to our policies in order to provide transparency regarding the collection and use of your personal data, the business purpose for that collection and use of your personal data, and the ways you are able to access, update and correct certain uses of your personal data.

The CCPA requires that we disclose, upon request from a California resident, certain information about our collection and use of their personal information over the past 12 months, including:

• The categories of personal information we collected about them.
• The categories of sources for the personal information we collected about them.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about them.

California residents also have the right to request that we delete any of their personal information that we collected and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from a California resident, we will delete (and direct our service providers to delete) their personal information from our records, unless an exception applies.

How does Higher Logic help your organization?

We have updated our Privacy Policy in light of CCPA so that California residents have access to and can use the applicable CCPA rights listed above. Data privacy is a priority for Higher Logic. Higher Logic recently achieved the  TrustArc  certification that confirms globally recognized privacy requirements, including Fair Information Practice Principles, OECD Privacy Guidelines, APEC Privacy Framework, and the EU-U.S. and Swiss-U.S. Privacy Shield Principles.

We made required changes and added functionality to our platforms in preparation for the GDPR in 2018, adding features that will now also be useful to our Subscribers in meeting their CCPA obligations.  Under the CCPA, with respect to our Subscribers, Higher Logic is considered a Service Provider, processing personal data on behalf of a Business, you, our Subscribers.  Should Higher Logic receive a request to know or a request to delete the personal data of an individual processed by Higher Logic on behalf of a Subscriber, Higher Logic will direct that request to the Subscriber.

Higher Logic offers a CCPA Addendum to our Master Subscription Agreement, further clarifying our respective roles and responsibilities in the handling personal data from California residents. Executing this CCPA Addendum will help your organization continue to transfer personal data to Higher Logic in a lawful manner and permit Higher Logic to receive and process that data on your behalf.