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Rogue Valley Technology Consulting

Your Personalized PrivacyAlign® Data Compliance Report Card

At Rogue Valley Technology Consulting, we are committed to simplifying technology for our clients. With that in mind, we’ve prepared a personalized report card for your business.

Your PrivacyAlign® Data Compliance Report Card provides a snapshot of your business's current data compliance status, offering practical insights and highlighting areas where improvements are needed. Use it to inform your next steps in protecting both your customers' privacy and your business’s integrity under the OCPA. 

Our expert consultants can help your business comply with data privacy laws in Oregon and beyond. Contact us for more information

This report has been prepared for , on .

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Executive Summary

As a business owner, protecting your customers’ data is part of your responsibility, but staying ahead of evolving privacy laws can be challenging. The Oregon Consumer Privacy Act (OCPA) introduces new requirements that may impact how you collect, store, and use personal information.

Understanding where your business stands is the first step toward compliance. The PrivacyAlign® Data Compliance Report Card is designed to help you assess your current data privacy practices, identify gaps, and take action. This tool will show whether your business meets OCPA standards and highlight steps to improve compliance.

Taking a proactive approach now can help you reduce risks, strengthen customer trust, and future-proof your business in an increasingly regulated digital landscape.

What is Data Privacy?

The Oregon Department of Justice defines privacy as, “the right to be left alone. Traditionally this means [individuals] have privacy in certain spaces, like at home. In the modern age, it also relates to control over information that companies collect. This is called data privacy.” (source)

Your customers’ data—such as their email address—might be used by your business for purposes like targeted marketing or advertising, but it ultimately belongs to them. This means they have the right to know how their data is collected, stored, and shared. They also have the right to access, correct, or delete it under the law.

Respecting these rights may be your legal obligation, and it also helps build trust and strengthen customer relationships.

Transparent data practices demonstrate your commitment to privacy, setting your business apart as one that values consumer rights and ethical data stewardship.

What is Personal Data?

Home Address

Email

Drivers License Or State Identification Number

Passport Information

Financial Account Number

Login Credentials

Browsing History On A Smart Tv

What is Sensitive data?

Racial Or Ethnic Background, Or Nationality Origin

Religious Beliefs

Mental/Physical Health Conditions/Diagnoses

Sexual Orientation

Citizenship Or Immigration Status

Status As Transgender Or Nonbinary

Status As A Crime Victim

Genetic Or Biometric Data

Specific Past Or Present Location

Personal Data Of A Child Under 13

Why Compliance is a Good Idea Now

You might be asking, what should I be doing now? As a business owner, you may have a legal responsibility to comply with one or more state’s Data Privacy laws, and even if you are not required to comply yet, aligning with data privacy regulations like OCPA is a good idea. Ensuring compliance can help you avoid penalties while protecting consumer trust and preparing for a regulatory landscape that is becoming increasingly stringent. 

Here are some reasons why compliance with data privacy laws is a good idea now:

  1. Upcoming Legislation & Expanding Regulations
    The OCPA is part of a growing trend of state-level privacy laws in the U.S. Following California, Virginia, and Colorado, more states are introducing comprehensive privacy laws, making it clear that businesses will soon need to comply with multiple overlapping regulations. Getting ahead of OCPA now ensures you're prepared for future changes.
  2. Alignment with CCPA and GDPR
    OCPA shares many similarities with CCPA and GDPR, such as consumer rights to access, delete, and correct their data, along with transparency requirements for businesses. If you're already compliant with GDPR or CCPA, you're in a strong position to meet OCPA’s standards—but there are still state-specific nuances to address.
  3. Consumer Expectations & Trust
    Data privacy is a legal issue, and a competitive advantage. Customers are becoming more aware of how their data is used, and businesses that prioritize privacy and transparency can differentiate themselves in the market. Clear privacy policies and robust data security measures foster trust and loyalty.
  4. Avoid Legal Consequences
    Non-compliance with privacy laws can result in significant legal challenges. The OCPA, like CCPA and GDPR, includes enforcement mechanisms that allow regulators to impose penalties for violations. Proactively implementing compliance measures helps mitigate legal and reputational risks.
  5. Compliance Now Saves Money
    Businesses that proactively adopt data privacy measures avoid steep fines, reduce long-term costs, and leverage affordable compliance solutions. Under OCPA and CCPA, fines can reach $7,500 per violation, and GDPR penalties can be as high as €20 million or 4% of global revenue. Additionally, the average cost of a data breach hit $4.35 million in 2022, but businesses that invested in compliance saved $1.76 million per breach (IBM, 2022). PrivacyAlign® helps businesses comply affordably before regulations tighten and costs rise.
  6. Operational Efficiency & Risk Management
    By establishing clear data governance policies, businesses can streamline operations and reduce the risk of data breaches, which can be costly in terms of both financial impact and public perception. Compliance also makes it easier to work with partners and vendors who require data security assurances.
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Compliance Check #1: Privacy Policy

A privacy policy is a legal document that informs users about how their data is collected, used, stored, and shared. It is a fundamental requirement for data compliance.

How It Supports Compliance:

  • Ensures transparency with users about your business’s data practices.
  • Helps your business comply with legal obligations and avoid fines.
  • Builds trust with your customers by demonstrating a commitment to data protection.

Your Privacy Policy status:

 
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Compliance Check #3: Consent for Sensitive Data – Obtaining Explicit Consent for the Collection of Sensitive Personal Information

When it comes to sensitive personal data—like health information, financial details, or biometric data—it's crucial to approach collection and processing with extra caution. Under the Oregon Consumer Privacy Act (OCPA), businesses are required to obtain explicit consent from users before collecting or processing this kind of information. Unlike general personal data, sensitive data requires a higher level of protection, as its misuse can lead to significant privacy risks.

This means your business must go beyond general data collection notices. You can’t just assume consent or bury it in lengthy terms and conditions. Instead, you must clearly inform users about what data you're collecting, why you're collecting it, and how it will be used. Then, you must actively obtain their consent before proceeding.

In practice, this could include:

  • Providing users with clear, visible options (such as checkboxes or opt-in forms) to confirm their consent.
  • Explaining the implications of data collection so users can make an informed decision—especially with regard to sensitive information.
  • Allowing users to withdraw their consent at any time, with simple mechanisms for doing so.
  • Ensuring consent is recorded for accountability, should any compliance audit arise.

Essentially, the goal is to ensure that sensitive personal information is handled responsibly and with full transparency, giving users the control they deserve over their private data. This step not only aligns your business with legal obligations but also builds trust with your customers, showing them that their privacy is a priority.

Your Consent for Sensitive Data status: TBD, based on our detailed evaluation of how well your business obtains, records, and manages consent for sensitive data. We will assess whether your processes clearly inform users about the type of sensitive information being collected, why it is being collected, and how it will be used. Our team will also review whether your consent mechanisms are user-friendly, transparent, and compliant—such as checkboxes or opt-in forms—and if users can easily withdraw consent at any time.

For businesses in Tier 3, we will provide a comprehensive review of your data collection practices and implement customized consent workflows for your sensitive data. For businesses in Tiers 1 and 2, we’ll provide practical instructions and recommendations to ensure that your consent process is clear, accountable, and fully aligned with OCPA requirements. By properly managing consent, your business not only fulfills legal obligations but also demonstrates to your customers that you respect their privacy and are committed to handling their sensitive data responsibly.

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Compliance Check #4: Minimize Data Collection

Data minimization is a key principle of the Oregon Consumer Privacy Act (OCPA), which focuses on ensuring businesses only collect the personal information that is absolutely necessary.Your business must limit the scope of data collection and evaluate whether you're gathering more information than required for your operations.

Under OCPA, your organization must ensure that only essential data is collected, stored, and processed, and whether you have clear policies around what data you need, why you need it, and how long you retain it.

Having a data minimization strategy helps reduce unnecessary exposure to data risks, supports user privacy rights, and ensures compliance with OCPA. 

Your Data Minimization Strategy status: TBD, based on our review of your data collection practices and retention policies. We’ll examine whether your business is collecting only the essential data needed for your operations and if you have clear guidelines on why this data is necessary, how it will be used, and how long it will be retained. By implementing a data minimization strategy, your business can reduce unnecessary exposure to privacy risks, enhance compliance with OCPA, and build greater trust with your customers.

For businesses in Tier 3, we will help you refine your data collection strategy, providing detailed recommendations to ensure you're limiting your data to only what’s necessary for specific purposes. For businesses in Tiers 1 and 2, we will guide you on how to evaluate and adjust your current data practices, helping you align with OCPA requirements and minimize unnecessary data collection.

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Compliance Check #6: Opt-Out Mechanisms

Opt-out mechanisms are essential for data compliance, allowing users to easily opt out of targeted advertising and the sale of their personal data. Additionally, starting January 1, 2026, businesses must honor universal opt-out signals, such as browser-based privacy preferences, to stay compliant with evolving privacy regulations. Implementing these mechanisms ensures your business respects consumer rights and avoids penalties.

Your Opt-Out Mechanism status:

Do Not Track (DNT) Support:  

Global Privacy Control (GPC) Support: 

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Compliance Check #7: Cookie Management

Cookie management is a critical part of data compliance, ensuring transparency and giving users control over their online privacy. A cookie banner is required to inform users about the types of cookies being used on your website, including whether they are essential or non-essential. It must also offer users the option to accept or reject non-essential cookies. This practice not only helps you comply with privacy laws but also builds trust with your customers by giving them control over their data and online experience.

Your Cookies Management status:

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Compliance Check #8: Data Protection Assessments

If your website processes data in a way that poses a heightened risk—such as through profiling, large-scale sensitive data collection, or tracking behavioral data—you are required to conduct Data Protection Impact Assessments (DPIAs) regularly. These assessments help identify and mitigate any potential privacy risks, ensuring that your business is proactive in safeguarding user data. By conducting these assessments, you comply with regulations like OCPA, which mandates this for high-risk data processing activities. Regular evaluations help protect your users' privacy, maintain compliance, and avoid costly fines.

Your Data Protection Assessment status: TBD, based on an assessment of your current practices. In Tier 1, we will provide a framework and instruction manual for you to conduct the assessment with your team or developer. In Tier 2, we will guide you through the process, helping you identify and address potential risks. In Tier 3, we will conduct a full Data Protection Impact Assessment for you, evaluating your data processing practices and providing actionable recommendations to mitigate risks and ensure compliance.

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Compliance Check #9: Third-Party Contracts

When sharing data with processors or third parties, it's crucial to ensure that contracts are in place that align with OCPA. These contracts, also known as Data Processing Agreements (DPAs), outline the responsibilities and obligations of both parties in handling personal data. They should specify how data is processed, stored, and protected, as well as the rights of individuals whose data is being shared.

The importance of these contracts is to mitigate risks and ensure that third parties follow the same data protection standards required by law. Without these agreements, you may face penalties for non-compliance.

Your Third Party Contracts status: Check with your legal team to review your compliance in this regard. 

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Compliance Check #10: Exclusions

Exclusions refer to specific types of data that may be exempt from certain data protection laws due to being subject to other regulations. For example, HIPAA (Health Insurance Portability and Accountability Act) governs healthcare data, while FERPA (Family Educational Rights and Privacy Act) regulates educational records. If your business processes any data that falls under these or other exemptions, it’s essential to identify it and tailor your data protection policies accordingly to ensure compliance with the relevant laws.

Your Exclusion status: TBD, based on an assessment of your data. In Tiers 1 and 2, we provide content in the Executive Summary to help you recognize whether any of your data may be exempt and offer guidance on how to handle such data appropriately. In Tier 3, we offer a more in-depth service, helping you assess your data practices and update your policies to reflect these exclusions, ensuring that your business remains fully compliant with both industry-specific regulations and broader data protection laws like OCPA and GDPR.

Get In Touch

Your PrivacyAlign® Data Compliance Report Card highlights your current data compliance status and identifies key areas for improvement. As regulations continue to evolve, it is essential to address these compliance gaps to protect your business and customers. Rogue Valley Technology Consulting is here to help at every step, offering tailored solutions to ensure your business stays compliant and minimizes risks. 

Whether you need guidance, implementation, or full-service support, we are ready to assist you in achieving robust data protection practices that build trust and ensure long-term success.