On June 1, 2020, in a surprise, last-minute filing, the office of the California Attorney General submitted the final CCPA final California Consumer Privacy Act (CCPA) proposed regulations to the California Office of Administrative Law (OAL).
What
does this mean for businesses subject to the CCPA?
Under
normal circumstances, the OAL would have 30 days to review the proposed
regulations for procedural compliance with California’s Administrative
Procedure Act; however due to the COVID-19 pandemic, this timeframe has been
extended by 60 additional days. This being said, the California Attorney
General requested an expedited review, asking the OAL to complete its review of
the final CCPA proposed regulations within the next 30 business days,
and that the proposed regulations become effective upon filing with the
Secretary of State. If the OAL honors this request, the regulations could become
effective as early as early July – shortly after the California Attorney
General will begin enforcement of the CCPA.
As
such, businesses should continue working toward compliance with the text of the
CCPA, as well as the text of the final proposed CCPA regulations.
Author
Brandon Moseberry
Brandon Moseberry advises global consumer, information technology, manufacturing, medical device, and financial institutions, among other clients, on a wide range of global data privacy, cybersecurity, direct marketing, social media, behavioral advertising, and related matters.
Author
Michael Egan
Michael advises clients across various industries, including global online businesses, pharmaceutical companies, healthcare providers, manufacturers, financial institutions, sourcing providers, retail companies, and other organizations regarding the legal aspects of global privacy and data protection, data security, information technology, and related restrictions on data collection and transfer.
Author
Lothar Determann
Lothar has been helping companies in Silicon Valley and around the world take products, business models, intellectual property and contracts global for nearly 20 years. He advises on data privacy law compliance, information technology commercialization, interactive entertainment, media, copyrights, open source licensing, electronic commerce, technology transactions, sourcing and international distribution at Baker McKenzie in San Francisco & Palo Alto.
Author
Gary Hunt
Gary is an associate in the Chicago office. His practice focuses on regulatory and transactional issues in global privacy and data protection, including cross-border data transfers, data security, data breach notification, global privacy, website privacy policies, behavioral advertising, and comprehensive compliance programs.
