Are Credit Unions Covered by the CCPA?

Organizations might rethink what they do with consumer data.

Those who have spent time critically thinking about the California Consumer Privacy Act can undoubtedly identify a number of ambiguities and uncertainties. Some of those may be resolved through the current legislative amendment process or the forthcoming Attorney General interpretive regulations. However, notwithstanding those efforts, there likely will be many unresolved issues when the CCPA becomes effective.

This article analyzes one such ambiguity – namely, whether the CCPA applies to credit unions. As discussed below, this uncertainty appears to have arisen out of the premise that the CCPA does not apply to non-profits. However, based on an analysis of the CCPA’s definition of “business” in the context of the unique nature of credit unions as well as industry guidance, the CCPA likely does apply to credit unions.