CPPA Underscores That Businesses Own CCPA Compliance – Even When Privacy Management Tools Fail

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