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Michael Egan

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On March 11, 2020, the California Attorney General released another set of revisions to the California Consumer Privacy Act (CCPA) draft implementing regulations. The regulations are not yet finalized (a public comment period for this most recent version is open until March 27, 2020), but below we highlight key changes and takeaways for businesses under the latest version of the regulations. Note that this round of revisions to the regulations largely consist of updates to…

With the advent of the novel coronavirus COVID-19, many organizations around the world are undergoing a seismic shift on an accelerated timeline towards telework or remote working for some or all employees. In addition to ensuring that the networks, VPNs, and other IT resources are capable of supporting such a shift, organizations that have not built such teleworking into their disaster preparedness plans should be aware of, and take steps to mitigate, the cybersecurity and…

Many employers in the US are grappling with appropriate efforts to contain and protect the workforce against COVID-19. Those efforts include employee and visitor screening activities that range from requiring all personnel to provide an affirmation upon admission to a worksite to taking vital signs or other hands-on screenings. But are those screening activities lawful under applicable privacy and confidentiality laws in the US? And what should employers do when they have reason to suspect…

On February 7, 2020, the California Attorney General released its revised draft implementing regulations for the California Consumer Privacy Act. The revised regulations are not yet final. The California AG will accept written comments regarding the updated regulations until 5:00 pm (PST) on Tuesday, February 25, 2020. The following is a high-level overview of the key new requirements under the updated regulations that are important for businesses to consider in connection with their CCPA compliance…

The European Union’s highest court, the Court of Justice of the European Union (CJEU), is evaluating the legitimacy of the EU standard contractual clauses (SCC). SCCs have been the bedrock of cross-border personal data transfers outside the EU for many years. Today, the advocate general (a.g.) has rendered an opinion on the Schrems II case. By way of brief background, Schrems II is a case before the Court of Justice of the European Union (CJEU)…

The California legislative session ended with a bang on September 13, when legislators passed several noteworthy amendments to the California Consumer Privacy Act (CCPA). The California governor has until October 13 to act on these amendments. We have outlined below the amendments that materially alter the original scope or requirements of the CCPA and that will impact CCPA compliance activities for many organizations. Limited Personnel ExemptionAssembly Bill 25, the amendment exempting personal information collected from…

The best time to plant a tree was 20 years ago. The second best time is now. – Chinese ProverbIn fewer than 6 months, the requirements of the California Consumer Privacy Act (“CCPA”) come into operation. With no sign that CCPA’s obligations will be materially watered down or preempted by federal legislation, companies that have not started preparing for CCPA need to do so as quickly as possible in order to meet the January 1,…