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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…

Along with changes brought by the CCPA, companies should be aware of other important privacy developments that went into effect in early 2020.  Notable changes to data breach notification laws in California, Illinois, Oregon, and Texas promise to have a significant impact on businesses experiencing security incidents and signal a movement towards stricter and more demanding requirements in this space.    California Amends Definition of Personal Information for Breach Notification         The definition of personal information…

In this episode of Connect On Tech, your host Brian Hengesbaugh is joined by Teresa Michaud, a partner in Baker McKenzie’s Los Angeles office. Together they will discuss the possible private litigation that may arise as a result of the California Consumer Privacy Act (CCPA). Tune in to learn: What clients are calling “the scariest aspect” of the CCPAHow class action plaintiffs might bring suit outside of the data breach contextTeresa’s practical tips for how…

In the flurry of bills relating to the California Consumer Privacy Act (CCPA), the California Legislature also enacted a law requiring data brokers to register, following a similar (but not identical) law in Vermont (see, https://iapp.org/news/a/analysis-vermonts-data-broker-regulation/) and attention by Congress, the FTC and advocates to data brokers in prior years (https://iapp.org/news/a/ftc-calls-for-legislative-action-to-regulate-data-brokers/). California lawmakers placed the broker law right before CCPA in the California Civil Code and clarified in Cal. Civ. Code §1798.99.88 that “Nothing ……

For many companies, January 1, 2020 became synonymous with the operative date of the California Consumer Privacy Act. However, manufacturers of Internet-connected devices must also keep in mind legislation that was signed into law on September 28, 2018 and became operative on January 1, 2020. This new law (2018 Cal. Legis. Serv. Ch. 886 (S.B. 327) (to be codified at Cal. Civ. Code § 1798.91.04(a)) (“IoT Law”) makes California the first state to specifically regulate…

What does this mean for covered businesses? Two important privacy law developments took place last week in California. On 10 October 2019, the California Attorney General (AG) published its proposed regulations under the California Consumer Privacy Act (CCPA), and on 11 October 2019, Governor Gavin Newsom signed several bills that were passed in mid-September amending the CCPA (click here for a summary of those amendments). In this alert, we summarize some of the key requirements…