Fullfilment of CCPA Verifiable Consumer Requests

Infrastructure development for communications company to comply with CCPA requests

Project Overview

In 2019, California passed the California Consumer Protection Act (CCPA) giving consumers control over all personal information in the possession of any organization doing business within the state. As a result of this legislation, within just four months, a US-based communications company needed a solution to process any consumer requests to access or delete information.

RevGen worked collaboratively with the client to deliver a fully automated end-to-end solution. Not only does this solution avert fines by complying with the law, it increases consumer transparency and trust which is the intent of the law. And it does so with a high degree of operational and IT efficiency, which keeps down the cost of delivering on consumer requests.

Client Challenge

  • Translate legislative requirements into concrete deliverables and assets eligible to be engaged by the consumer
  • Assess technology infrastructure needs to determine what to technologies to repurpose versus what new technologies needed to be purchased and injected into the environment
  • Gain a deep understanding of the regulation such that they could properly identify and document personal information (PI) across the business
  • Create a consumer output file in compliance with the law, generating a positive customer experience
  • Design an effective customer experience such that the consumer fully understands the business’s policy in relationship to the law and can easily submit a request

Solution

Program Management Function

Upon joining the client team, RevGen quickly established a PMO function.  The team assessed the situation and established five workstreams to address project needs: (1) customer experience, (2) output file generation, (3) personal information identification, (4) technology infrastructure development, and (5) legislative assessment. Throughout the project, RevGen worked with the workstream leads in making key decisions surrounding technology, business logic, process and more to ensure the system was developed at optimal level.

Governance Model

The PMO established a cross-functional team meeting to support project milestones and ensure smooth handshakes throughout the process. In addition, 1:1 meetings were created to drill into specific issues encountered by each workstream.

Personal Information Data Collection Methodology

RevGen developed a PI data collection methodology which was rolled out to twenty business units. The approach met the requirements defined by the technology team and generated the minimum-required output file. Data collection began with the end in mind.

Customer Experience

RevGen helped the business focus on the consumer experience. This included working with the cross-functional team to identify how a consumer would engage the Privacy Rights Center (submission engine, policy, FAQs, web-links, etc.). Lastly, RevGen worked with the various workstream leaders to assist in making key decisions surrounding technology, business logic, process or whatever else was needed such that the system developed was done so at an optimal level.

 

Results

Fully Automated End-to-End Solution

The fully automated end-to-end solution is capable of receiving requests, issuing requests to business units for data inputs and processing said inputs such that an output file can automatically published to the consumer.

Consumer Transparency and Trust

The solution provides each consumer visibility into the information the organization maintains on them, creating an environment of trust and transparency.

Operational Efficiency

The infrastructure automates 80% of the request process, creating operational, technical, and other efficiencies within the business, which significantly lowers the overall delivery cost per file.

Success Stories

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