BILL ANALYSIS                                                                                                                                                                                                    Ó





                             SENATE JUDICIARY COMMITTEE
                         Senator Hannah-Beth Jackson, Chair
                             2015-2016  Regular  Session


          AB 83 (Gatto)
          Version: August 19, 2016
          Hearing Date: August 24, 2016
          Fiscal: No
          Urgency: No
          TH   

                            PURSUANT TO SENATE RULE 29.10
          
                                        SUBJECT
                                           
                                    Personal Data

                                      DESCRIPTION  

          This bill modifies the scope of "personal information" for which  
          businesses must implement and maintain reasonable security  
          procedures and practices in order to protect the information  
          from unauthorized access, destruction, use, modification, or  
          disclosure.  Specifically, this bill adds geolocation  
          information, tax identification numbers, passport numbers,  
          biometric information, military identification numbers, and  
          government issued employment identification numbers, to the list  
          of protected personal information.  This bill reduces the scope  
          of protected personal information that falls within the  
          definition of "health insurance information," and expands the  
          scope of personal information excluded from these protections  
          when the information has been made publicly available.  This  
          bill also specifies certain criteria for determining the  
          reasonableness of security procedures and practices, including  
          the cost of implementing these procedures and practices, and the  
          size of the business tasked with such responsibilities.

                                      BACKGROUND  

          In 2004, the Legislature enacted AB 1950 (Wiggins, Ch. 877,  
          Stats. 2004), which established broadly applicable security  
          standards for the protection of personal information about  
          California residents that is owned or leased by businesses.   
          Before AB 1950 became law, federal and state laws generally  









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          provided only industry-specific requirements for the protection  
          of personal information.  For example, state medical privacy  
          laws like the Confidentiality of Medical Information Act (Civ.  
          Code Sec. 56 et seq.) govern the use and sharing of medical  
          information by health care entities, but do not regulate this  
          information when obtained by other businesses.

          AB 1950 required businesses that own or license personal  
          information -- including social security numbers, payment card  
          information, and medical information -- about a California  
          resident to implement and maintain reasonable security  
          procedures and practices appropriate to the nature of the  
          information, to protect the personal information from  
          unauthorized access, destruction, use, modification, or  
          disclosure.  Despite this requirement, the frequency at which  
          data breaches expose the personal information of California  
          residents has increased dramatically since 2004.  An October  
          2014 article in the Los Angeles Times made the following  
          observations about this trend:

            Data breaches soared last year in California as cybercriminals  
            leaped over digital security gates to endanger the personal  
            data of millions of consumers, California Atty. Gen. Kamala  
            Harris said.  Harris, in a report released Tuesday,  
            highlighted the effect that headline-producing data breaches  
            had on the Golden State: two massive hacks last year at Target  
            Corp. and daily deals website LivingSocial each hit roughly  
            7.5 million Californians.  In all, 18.5 million people in the  
            state had their data stolen last year, a more than 600  
            [percent] jump from 2012.  The number of breaches reported to  
            Harris' office climbed 28 [percent] to 167, and is expected to  
            rise again in 2014.  "Data breaches ? threaten the privacy,  
            the security and the economic well-being of consumers and  
            businesses," Harris said at a news conference in Los Angeles. 

            California residents aren't any more prone to data hijacking  
            than others, but an unusual state law requires businesses and  
            state agencies to notify customers of any breach involving  
            more than 500 accounts.  That law resulted in the California  
            Data Breach Report, which underscored the difficulties faced  
            by companies who are constantly racing against wily thieves to  
            secure sensitive information.  The parade of companies that  
            has been targeted recently by hackers includes Home Depot,  
            Michaels, Neiman Marcus and P.F. Chang's.









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            Security experts predict that the number of breaches,  
            especially on a big scale, will keep growing.  "The data  
            breaches are going to continue and will probably get worse  
            with the short term," said Jim Penrose, former chief of the  
            Operational Discovery Center at the National Security Agency.
            . . .
            Harris said businesses need to adopt stronger encryption  
            technologies that safeguard sensitive consumer data.  And  
            retailers must make their breach notifications to consumers  
            more visible and should upgrade their systems to handle  
            payment cards equipped with microchips, which make cards more  
            difficult to counterfeit, Harris said.  (Shan Li and Andrew  
            Khouri, Data Breaches Jump in California and are Expected to  
            Keep Climbing, Los Angeles Times (Oct. 28, 2014)  
             [as of Aug. 22, 2016].)

          This bill responds to the growing frequency of data breaches by  
          adding additional requirements to the "reasonable security  
          procedures and practices" that businesses are mandated to  
          implement under existing law with respect to personal  
          information.  This bill also adds new categories of personal  
          information subject to protection, including individual tax  
          identification numbers, passport numbers, military  
          identification numbers, government issued employment  
          identification numbers, geolocation information, and biometric  
          information.

          An earlier version of this bill was heard by this Committee on  
          July 7, 2016, and was approved on a vote of 5-1.  This bill was  
          subsequently amended and has been re-referred to this Committee  
          pursuant to Senate Rule 29.10.

                                CHANGES TO EXISTING LAW
           
           Existing law  , the California Constitution, provides that all  
          people are by nature free and independent and have inalienable  
          rights.  Among these are enjoying and defending life and  
          liberty, acquiring, possessing, and protecting property, and  
          pursuing and obtaining safety, happiness, and privacy.  (Cal.  
          Const, art. I, Sec. 1.)

           Existing law  requires state agencies, under the Information  
          Practices Act (IPA), to establish appropriate and reasonable  
          administrative, technical, and physical safeguards to ensure  








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          compliance with the IPA, to ensure the security and  
          confidentiality of records, and to protect against anticipated  
          threats or hazards to their security or integrity which could  
          result in any injury.  (Civ. Code Sec. 1798.21.)

           Existing law  requires a business that owns, licenses, or  
          maintains personal information about a California resident to  
          implement and maintain reasonable security procedures and  
          practices appropriate to the nature of the information, to  
          protect the personal information from unauthorized access,  
          destruction, use, modification, or disclosure.  (Civ. Code Sec.  
          1798.81.5(b).)

           Existing law  requires a business that discloses personal  
          information about a California resident pursuant to a contract  
          with a nonaffiliated third party that is not subject to the  
          restriction above to require by contract that the third party  
          implement and maintain reasonable security procedures and  
          practices appropriate to the nature of the information, to  
          protect the personal information from unauthorized access,  
          destruction, use, modification, or disclosure.  (Civ. Code Sec.  
          1798.81.5(c).)

           Existing law  defines "personal information" to mean an  
          individual's first name or first initial and his or her last  
          name in combination with any one or more of the following data  
          elements, when either the name or the data elements are not  
          encrypted or redacted:
           social security number;
           driver's license number or California identification card  
            number;
           account number, credit or debit card number, in combination  
            with any required security code, access code, or password that  
            would permit access to an individual's financial account; 
           medical information; and
           health insurance information.  (Civ. Code Sec. 1798.81.5(d).)

           Existing law  specifies that "personal information" also includes  
          a username or email address in combination with a password or  
          security question and answer that would permit access to an  
          online account.  (Civ. Code Sec. 1798.81.5(d).)

           Existing law states that "personal information" does not include  
          publicly available information that is lawfully made available  
          to the general public from federal, state, or local government  








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          records.  (Civ. Code Sec. 1798.81.5(d).)

           This bill  modifies the above provision to state that "personal  
          information" does not include publicly available information  
          that is lawfully made available to the general public.

           This bill  expands the definition of "personal information" to  
          include the following:
           an individual tax identification number, passport number,  
            military identification number, or government issued  
            employment identification number;
           geolocation information; and
           biometric information.
          
           This bill  states that for purposes of the above provisions,  
          "reasonable security procedures and practices" as they pertain  
          to the storage and transmission of personal information shall  
          require the security of that information to the degree that any  
          reasonably prudent business would provide, including undertaking  
          reasonable efforts, appropriate to the nature of the  
          information, to:
           identify reasonably foreseeable internal and external risks to  
            the security of personal information that could result in the  
            unauthorized disclosure, misuse, alteration, destruction, or  
            other compromise of the information; and
           establish, implement, and maintain safeguards reasonably  
            designed to secure the personal information, including, but  
            not limited to, protecting against unauthorized access,  
            acquisition, destruction, use, modification, or disclosure of  
            the information; and
           regularly assess the sufficiency of these safeguards to  
            control reasonably foreseeable internal and external risks,  
            and evaluate and adjust those safeguards in light of the  
            assessment.

           This bill  states that the reasonableness of the security  
          procedures and practices appropriate to the nature of the  
          information shall be determined in light of all of the  
          following:
           the type of personal information under the business's control;
           the foreseeability of threats to the security of the  
            information;
           the existence of widely accepted practices in administrative,  
            technical, and physical safeguards for protecting personal  
            information;








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           the cost of implementing and regularly assessing the  
            safeguards; and
           the size of the business.

           This bill  defines "geolocation information" to mean location  
          data generated by a consumer device capable of connecting to the  
          Internet that directly identifies the precise physical location  
          of the identified individual at particular times and that is  
          compiled and retained.  This bill specifies that geolocation  
          information does not include the contents of a communication or  
          information used solely for 911 emergency purposes.

           This bill  defines "biometric information" to mean data generated  
          by automatic measurements of an individual's fingerprint, voice  
          print, eye retinas or irises, identifying DNA information, or  
          unique facial characteristics, which are used by the owner or  
          licensee to uniquely authenticate an individual's identity.

           This bill  modifies the definition of "health insurance  
          information" to mean an individual's health insurance policy  
          number or subscriber identification number, any unique  
          identifier used by a health insurer to identify the individual,  
          or any medical information in an individual's insurance  
          application and claims history, including any appeals records.

                                        COMMENT
           
           1.Stated need for the bill
           
          According to the author:

            The California Information Practices Act of 1977 sets the  
            rules for the collection, maintenance and dissemination of  
            information that identifies an individual to guarantee that  
            privacy is protected to the greatest extent possible.   
            California's data protection statutes, among other things,  
            require businesses that own, license, or maintain personal  
            information about Californians to provide reasonable security  
            for that information.

            Before the United States was rocked by a December 2013 data  
            breach at Target stores that captured the information of  
            almost 40 million credit and debit cards, many consumers did  
            not think about the protection of their personal and  
            transaction data.  Since the Target incident, however, data  








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            breaches have haunted consumers, businesses, and government  
            entities, alike.   

            While credit card information is valuable and breaches have  
            affected businesses like Home Depot, Neiman Marcus and JP  
            Morgan Chase, credit card information is not the only lure.   
            Hackers have hit different branches of California government,  
            including the Bureau of Automotive Repair, Mt. Diablo Unified  
            School District and the California Department of Public  
            Health.  In May 2014, hackers breached a database owned by  
            ride-sharing app Uber, which contained the names and drivers'  
            license numbers of 50,000 of its drivers.  Then, in November  
            2014, Sony hackers not only released five unreleased films,  
            but they also posted 47,000 employee Social Security numbers  
            online, which appeared on more than 600 publicly-posted files.  
             These numbers appeared with other personal information, such  
            as full names, dates of birth, and home addresses.  

            One of the most alarming parts of increasingly-frequent  
            cyberattacks is the risk of breached biometric information,  
            which entities and businesses are storing at an alarming rate.  
             In 2013, a German hacking group discovered how to breach  
            Apple's biometric security system using a high-resolution  
            image of a fingerprint, and in 2015, the Federal Office of  
            Personnel Management revealed that 5.6 million people's  
            fingerprints were stolen as part of a larger breach.  While  
            biometric information makes it easier to prove and  
            authenticate your own identity, coupled with it are increased  
            security concerns.  Unlike a debit card, password or even  
            social security number, an individual's fingerprint, iris  
            pattern, or voice print cannot be changed with the stroke of a  
            keyboard.  

            In today's world of computer and internet-based data storage,  
            no information is exempt or unattractive to those wanting to  
            breach our privacy and pry into our personal lives.  Consumers  
            need the assurance that their data is being stored at robust  
            standards that are as flexible and timely as the changing  
            technology landscape.

           2.Fundamental right to privacy
           
          The right to privacy is a fundamental right protected by article  
          I, section 1 of the California Constitution.  The Legislature  
          has expressly declared that "all individuals have a right of  








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          privacy in information pertaining to them," and has found that: 

            (1) The right to privacy is being threatened by the  
            indiscriminate collection, maintenance, and dissemination of  
            personal information and the lack of effective laws and legal  
            remedies.

             (2) The increasing use of computers and other sophisticated  
            information technology has greatly magnified the potential  
            risk to individual privacy that can occur from the maintenance  
            of personal information.

             (3) In order to protect the privacy of individuals, it is  
            necessary that the maintenance and dissemination of personal  
            information be subject to strict limits. (Civ. Code Sec.  
            1798.1.)  
          This bill seeks to build upon the fundamental right to privacy  
          by expanding the scope of personal information required to be  
          kept reasonably secure under existing law.  The Civil Code  
          imposes a general obligation on all businesses "to implement and  
          maintain reasonable security procedures and practices."  (Civ.  
          Code Sec. 1798.81.5(b).)  Already, businesses must reasonably  
          protect California residents' social security numbers, driver's  
          license or California ID card numbers, financial account  
          numbers, and medical information from unauthorized access and  
          use.  This bill would add, among other things, individual tax  
          identification numbers, passport numbers, geolocation  
          information, and biometric information to the list of protected  
          "personal information."

          As authentication technologies move beyond usernames and  
          passwords, the use of biometric information to secure sensitive  
          accounts and computer systems is likely to grow, making it an  
          attractive target for hackers.  Personal information like tax  
          identification numbers, passport numbers, and other  
          government-issued ID numbers, may be used by some to commit  
          identity theft.  And locational information, particularly that  
          which covers a long time period, could be used to learn a great  
          deal of sensitive information about a person.  As the U.S.  
          Supreme Court recently noted, this sort of information could  
          enable one to "ascertain, more or less at will, [the] political  
          and religious beliefs, sexual habits, and so on" of an  
          individual.  (United States v. Jones (2012) 132 S. Ct. 945,  
          955-956 [internal citations and quotation marks omitted].)   
          Adding these additional classes of data to the existing list of  








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          personal information subject to reasonable security protection  
          will help ensure that Californians' fundamental right to privacy  
          is protected.

           3.Limiting existing protections
           
          While certain aspects of this bill enhance the protection of  
          sensitive personal information, other recently amended sections  
          of the bill could greatly reduce or limit the scope of existing  
          protections.  Under existing law, for example, personal  
          information exempted from the data security standards in this  
          section of the Civil Code includes publicly available  
          information that is lawfully made available to the general  
          public from federal, state, or local government records.  This  
          bill would enlarge the scope of personal information subject to  
          this exemption beyond government records to include "publicly  
          available information that is lawfully made available to the  
          general public."  Such a change, without further clarification,  
          could greatly enlarge the scope of information subject to the  
          current "public records" exemption.  According to a coalition of  
          privacy organizations opposed to the amended version of this  
          bill:

            [e]xcept where existing law specifically prohibits disclosure  
            of certain types of personal information, this information  
            could otherwise be made lawfully available to the general  
            public and would therefore no longer be considered personal  
            information . . . This revised definition would mean that  
            personal information from social media accounts, fitness  
            applications, and even other more sensitive personal health  
            and educational data would be exempt from the protections  
            outlined in both the current law and the proposed amendments.   
            The exemption also implicates information that someone could  
            observe from the street, such as a person's entrance to an AA  
            meeting, placing it outside the definition of personal  
            information.  This change to existing law would represent an  
            enormous step backwards for California's consumer privacy and  
            protection laws.

          Recent amendments to this bill also re-define the term "health  
          insurance information" - a category of personal information  
          protected under existing law - in a manner that restricts the  
          scope of personal information subject to protection.  According  
          to the opposition coalition:









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            [c]urrent law defines all information contained in an  
            individual's insurance application and claims history -- not  
            only that which is purely medical in nature -- as personal  
            health insurance information.  Such documents contain a wealth  
            of personal information and, as such, are afforded protections  
            under current law. Recent amendments to AB 83, however, limit  
            the definition of health insurance information only to include  
            the specific "medical" information, thereby narrowing the  
            scope of information afforded these protections by removing  
            existing protections for other sensitive information included  
            as part of an individual's health insurance information.

           4.Improved data security standards
           
          Existing law requires businesses that own, license, or maintain  
          personal information to implement and maintain reasonable  
          security procedures and practices to protect the information  
          from unauthorized access, destruction, use, modification, or  
          disclosure.  (Civ. Code Sec. 1798.81.5(b).)  This bill would  
          refine this existing duty by providing businesses with guidance  
          on what constitutes "reasonable security procedures and  
          practices."  Specifically, this bill would require businesses to  
          identify reasonably foreseeable internal and external risks to  
          the security of personal information, and to establish,  
          implement, and maintain safeguards reasonably designed to ensure  
          the security of that information, as soon as such information is  
          acquired.  More importantly, this bill would place a continuing  
          duty on businesses to regularly assess the sufficiency of the  
          safeguards in place to control reasonably foreseeable internal  
          and external risks, to evaluate and adjust those safeguards in  
          light of the assessment.

          As the recent data breach at the Office of Personnel Management  
          made clear,<1> even state-of-the-art data security systems must  
          continually assess their vulnerability to unauthorized  
          penetration and intrusion, especially when faced with persistent  
          threats.  This bill would require businesses that own, license,  
                                                                                       ---------------------------
          <1> Last year, the Office of Personnel Management suffered a  
          massive data breach that revealed the personal information of an  
          estimated 4 to 18 million federal workers, including many with  
          secret-level security clearances.  (See Adam Elkus, The  
          Devastating Breach of US Government Data Highlights an Illusory  
          Cybersecurity Paradox, Business Insider (Jun. 18, 2015)  
           [as of Aug. 23, 2016].)








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          or maintain personal information about California residents to  
          regularly evaluate the security procedures and practices they  
          use to protect that information in light of reasonably  
          foreseeable threats.  This continuing obligation would bring  
          California's business security standard more in-line with the  
          standard required of state agencies, which requires agencies to  
          establish appropriate and reasonable administrative, technical,  
          and physical safeguards to ensure the security and  
          confidentiality of records, and to protect against anticipated  
          threats or hazards to their security or integrity which could  
          result in injury.  (Civ. Code Sec. 1798.21.)

           5.Evaluating "reasonableness"
           
          This bill, like existing law, requires businesses to implement  
          security procedures and practices that are "reasonable" in  
          nature.  This bill would provide guidelines to help businesses  
          determine what security measures are reasonable by stating that  
          the reasonableness of security procedures and practices shall be  
          determined in light of the following:
           the type of personal information under the business's control;
           the foreseeability of threats to the security of the  
            information;
           the existence of widely accepted practices in administrative,  
            technical, and physical safeguards for protecting personal  
            information; and
           the cost of implementing and regularly reviewing the  
            safeguards.

          Although not set out explicitly in existing law, a reviewing  
          court would likely consider these factors, and others, when  
          determining whether a business has acted reasonably in  
          protecting the personal information of California residents.

          Recent amendments, however, add a further condition to the  
          reasonableness of security practices and procedures based on the  
          size of the business holding personal information - a concept  
          that is completely new to California's data security law.  Under  
          existing law, all businesses that hold covered personal  
          information are subject to the same standard of care for  
          securing that covered information, regardless of their size or  
          technological sophistication.  To the extent standards of care  
          differ in this area of California law, they differ based upon  
          the nature of the information held and the related threat of  
          misappropriation or breach, recognizing that some additional  








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          security measures may be needed to protect data that is more  
          valuable to a hacker or data thief because of its relative value  
          in the underground market for stolen information.  Existing law  
          does not evaluate the reasonableness of security measures based  
          on the size of a business, its market capitalization, the  
          technological prowess of its employees, or any other factor  
          unrelated to the information itself.  This proposed change to  
          the reasonableness standard, in effect, means that the same  
          sensitive information held by two different sized businesses  
          would receive different levels of protection, even though the  
          harm resulting from a breach would be the same.  Such a change  
          could greatly expose Californians' personal information to  
          breach just because it happens to be held by, for example, a  
          small startup company instead of Amazon.com or Google.

           1.Other opposition concerns
           
          The coalition of privacy organizations opposed to this bill also  
          raise concerns with the proposed definitions of "geolocation"  
          and "biometric" information as modified by the latest round of  
          amendments.  They write:

            The definition of "geolocational information," as amended,  
            eliminates the clear language previously contained in the bill  
            and replaces it with a series of loopholes that exempt the  
            vast majority of geolocational tracking activities from  
            coverage under this bill.  Specifically, the definition:
                 recognizes geolocation information only when that  
               information is generated by "a consumer device capable of  
               connecting to the internet."  This definition exempts  
               information contained from cell phones and electronic  
               devices that do not directly connect to the internet.   
               Because this definition recognizes geolocation only when  
               that information is "generated by a consumer device," it  
               also exempts geolocational information or coordinates that  
               are collected from satellites and cell phone towers . . .
                 requires that the specific individual responsible for  
               generating the geolocational information must be directly  
               identifiable in order to be included in the definition.  
               This provides an enormous loophole in which businesses and  
               technology providers can claim they were unsure who  
               "specifically" was using a device or application at the  
               time the coordinates were generated . . .
                 requires that the information "directly identifies the  
               precise physical location of the identified individual at  








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               particular times."  With no definition of "precise,"  
               particularly when this language is coupled with "at  
               particular times," this language appears to exempt data  
               collected through approximate, but still easily  
               identifiable, coordinates, thereby creating another large  
               loophole.
                 requires that in order to be considered, the information  
               must be "compiled and retained" by the entity.  Given that  
               neither of these words are defined, it is unclear who and  
               what would fall under the scope of this definition . . .  
               The definition appears to also exempt out data simply  
               collected through the use of a device or application and  
               immediately transferred to a third-party service provider,  
               implying that no one is responsible for securing the  
               information.

            The definition of "biometric information" is similarly  
            problematic.  It includes only a list of some types of  
            biometric information and is not representative of the broad  
            scope of biological and behavioral information used to  
            identify and authenticate individuals . . . The definition as  
            amended is extremely limited and will result in the same types  
            of data, with the same security implications, being subject to  
            different requirements based upon their intended use - even if  
            the data itself could in fact be used in the same manner.
           Support  :  California Credit Union League; Utility Reform Network

           Opposition  :  American Civil Liberties Union of California;  
          California Grocers Association; Consumer Federation of  
          California; CTIA - The Wireless Association; Direct Marketing  
          Association; Electronic Frontier Foundation; Privacy Rights  
          Clearinghouse; World Privacy Forum

                                        HISTORY
           
           Source  :  Author

           Related Pending Legislation  :

          SB 1444 (Hertzberg, 2016) requires state agencies that own or  
          license computerized data that includes personal information to  
          prepare a security plan that details the agency's strategy to  
          respond to a security breach of that information and its  
          associated consequences.  The bill lists certain minimum  
          requirements to be included in an agency's security plan,  








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          including a requirement to inventory personal information stored  
          or transmitted by the agency and procedures for facilitating  
          communication between an incident response team, agency  
          officials, and individuals affected by a breach.  The bill is on  
          the Senate inactive file.

           Prior Legislation  :

          AB 1541 (Committee on Privacy and Consumer Protection, Ch. 96,  
          Stats. 2015) added health insurance information, as defined, and  
          a username or email address combined with a password or security  
          question and answer for access to an online account, to the  
          definition of "personal information" for which businesses must  
          implement and maintain reasonable security procedures and  
          practices to protect the information from unauthorized access,  
          destruction, use, modification, or disclosure.

          AB 1710 (Dickinson, Ch. 855, Stats. 2014) amended California's  
          Data Breach Notification Law to require a person or business to  
          offer appropriate identity theft prevention and mitigation  
          services to an affected person at no cost for not less than 12  
          months if the person or business was the source of a data  
          breach.  This bill also prohibited the sale, advertisement for  
          sale, or offer to sell an individual's social security number.

          AB 1950 (Wiggins, Ch. 877, Stats. 2004) required a business that  
          owns or licenses personal information about a California  
          resident to implement and maintain reasonable security  
          procedures and practices to protect personal information from  
          unauthorized access, destruction, use, modification, or  
          disclosure.  AB 1950 also required a business that discloses  
          personal information to a nonaffiliated third party to require  
          by contract that those entities maintain reasonable security  
          procedures.


           Prior Vote  :

          Senate Judiciary Committee (Ayes 5, Noes 1)
          Assembly Floor (Ayes 66, Noes 4)
          Assembly Privacy and Consumer Protection Committee (Ayes 9, Noes  
          1)

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