Disney Settlement Offers a Playbook for CA AG's Opt-Out Expectations

Data strategy and privacy attorney Rachel Marmor was quoted in a Cybersecurity Law Report article analyzing California Attorney General (AG) Rob Bonta's record-setting California Consumer Privacy Act (CCPA) settlement with the Walt Disney Company and its implications for opt-out compliance. The article examined how the settlement signals heightened expectations around account-wide opt-outs, backend technical integration and privacy governance, particularly for companies operating across multiple services. Ms. Marmor specifically identified the post-acquisition period as a vulnerable spot for noncompliance risks and advised businesses to act quickly after closing to bring a target company under privacy protocols.

"That is not going to always be doable on day one in a lot of situations," she said. "But once you start reaping the benefits of some level of alignment, that seems to be where regulators want you to be offering a privacy approach that covers all of the company's units, whether old or new."

Ms. Marmor also co-authored a Holland & Knight alert on this topic.

READ: Disney Settlement Offers a Playbook for CA AG's Opt-Out Expectations (Subscription required)