The California Privacy Protection Agency (“CPPA”) has made it abundantly clear: privacy compliance isn’t just about publishing the right disclosures – it’s about whether your systems actually work. On May 6, the agency fined Todd Snyder, Inc. $345,178 for failures that highlight a growing regulatory focus on execution of California Consumer Privacy Act (“CCPA”) compliance. The action sends a powerful message: even well-resourced companies are not insulated from enforcement if they don’t actively test and manage how privacy rights are honored in practice.

Not Just Tools – Working Tools

The action against Todd Snyder was rooted in executional failure. The company had a portal in place for consumer rights requests, but it wasn’t processing opt-out submissions – a failure that lasted for roughly 40 days, according to the CPPA. The cookie banner that should have enabled consumers to opt out of cookie tracking would disappear prematurely, preventing users from completing their requests.

The company further required users to verify their identity before opting out and requested sensitive personal information, such as a photograph of their driver’s license. The CPPA determined this was not only unnecessary, but a violation in itself. The allegations around improper verification reflect concerns raised in a CPPA Enforcement Advisory issued last year, which cautioned businesses against collecting excessive information from consumers asserting their privacy rights.