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March 16, 2026 - In the News

Kathryn Rattigan Quoted on Disney CCPA Opt-Out Settlement

Cybersecurity Law Report
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Data Privacy + Cybersecurity team partner Kathryn Rattigan was quoted in an article titled “Disney Settlement Offers a Playbook for CA AG’s Opt-Out Expectations,” published in Cybersecurity Law Report on March 11, 2026. The article highlights the settlement between the California Attorney General and the Walt Disney Company resolving allegations that Disney violated the California Consumer Protection Act by failing to honor consumer requests to opt out of the sale or sharing of their data across all devices and services linked to their Disney accounts and the shift by regulators in placing more accountability on businesses to protect consumer data.

“A key provision of the settlement is the vendor oversight expectation,” said Kathryn, highlighting that main business remains responsible even if a third-party handles the processing of data. “You can outsource processing, but you cannot outsource accountability.”

Kathryn also comments on how regulators are shifting from high-level policy enforcement to deep technical and back-end scrutiny of consumer privacy rights, stating, “The bottom line: businesses should assume enforcement is now going to focus on whether privacy rights are actually executable in-product, end-to-end, across identities, devices and downstream partners.”

To read the article, click here.