What is a Service Provider under the CCPA?
Elements:
- Legal entity
- For profit or financial benefit
- Process “information” (not PI) “on behalf of a business”
- Business discloses PI for business purpose
- Disclosure pursuant to a written contract
- Contract prohibits recipient from retaining, using or disclosing PI for purposes other than in the contract
CCPA § 1798.140 (v)
An entity can be a deemed service provider if it is directed to connect personal information on behalf of a business. CCPA Regs § 999.314.
A service provider that is a business must comply with the CCPA. CCPA Regs § 999.314.
Service providers who are businesses cannot use personal information of on consumer to provide services to another consumer. CCPA Proposed Regs § 999.314.