In less than two months, on January 1, 2023, the California Consumer Privacy Act (CCPA) as revised by the California Privacy Rights Act (CPRA) will take effect fully in the job applicant and employment context. And with respect to job applicants and personnel, businesses subject to the CCPA will be required to (i) issue further revised privacy notices, (ii) be ready to respond to data subject requests, (iii) have determined if they sell or share…
Businesses that have implemented measures to comply with the California Consumer Privacy Act of 2018, as amended by the California Consumer Rights Act of 2020 (“CCPA”) can leverage some of their existing vendor contract terms, website disclosures and data subject rights response processes to satisfy requirements under the Colorado Privacy Act (“CPA”). However, the CPA, and the recently published proposed CPA Rules, (located here), contain certain unique and prescriptive requirements that may warrant taking a…
This week, the California Privacy Protection Agency (“CPPA”) released modified proposed regulations (“Modified Regulations”) for compliance with the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), and an explanation of the proposed changes, ahead of its upcoming Board Meetings. It is expected that the CPPA will discuss, and possibly adopt or modify further, the Modified Regulations during the CPPA Board Meetings which are scheduled for October 21-22 and October 28-29, 2022.…
Overview On September 23, 2022, the California Privacy Protection Agency (CPPA), in an open meeting, invited the public to listen in and provide comments on the agency’s current agenda. This five-hour meeting was facilitated by Chairperson Jennifer Urban. Based on the comments aired in the meeting, the public and other stakeholders (such as the business community) seemed interested in updates about the delayed California Privacy Rights Act (CPRA) regulations (originally expected in July 2022) and…
California recently enacted the California Age-Appropriate Design Code Act (“Act”) with the stated intention of requiring businesses to consider the best interests of minors under the age of 18 when designing, developing and providing online services. If your business currently offers online services that are likely to be accessed by minors in California, you should consider starting to prepare Data Protection Impact Assessments in accordance with the Act as soon as possible because the law…
In brief The California Privacy Rights Act of 2020 (CPRA) amended the California Consumer Privacy Act of 2018 (CCPA) with most changes taking effect on 1 January 2023 with a twelve-month look-back. Limited exceptions concerning the personal data of employees and business contacts will expire. The new California Privacy Protection Agency (CPPA) has published draft regulations that will, once finalized, expand on the rules in the statute and existing regulations from the California Attorney General. The CPPA is…
In advance of its June 8 public board meeting, the California Privacy Protection Agency (“CPPA”) has released draft regulations intended to implement and interpret new requirements under the California Privacy Rights Act (“CPRA”). In addition to codifying the new obligations under the CPRA (e.g., the right to correct, right to opt out of “sharing”), the Draft Regs include helpful illustrative examples and also provide details regarding certain new obligations, which we’ve summarized below. Key Takeaways…
2022 is looking to be an unprecedented year for California companies’ privacy law obligations. The California Privacy Rights Act (CPRA) takes effect on January 1, 2023 with a twelve-month look-back that also applies to the personal data of employees and business contacts. The new California Privacy Protection Agency is preparing regulations that will sit on top of existing rules from the California Attorney General. Meanwhile, the California Legislature is enacting privacy laws even though it has not…
2022 is looking to be an unprecedented year for California companies’ privacy law obligations. The California Privacy Rights Act (CPRA) takes effect on January 1, 2023, with a twelve-month look-back that also applies to the personal data of employees and business contacts. The new California Privacy Protection Agency is preparing regulations that will sit on top of existing rules from the California Attorney General. Meanwhile, the California Legislature is enacting privacy laws even though it has not…
In brief On “Privacy Day” – California Attorney General Rob Bonta announced an investigative sweep targeted at the data collection practices of businesses running consumer loyalty programs in California and issued notices of non-compliance to a number of “major corporations” in the retail, home improvement, travel, and food services industries. Such loyalty programs offered financial incentives to consumers (e.g., discounts, free items, and other rewards) in exchange for their personal information. Under the California Consumer Privacy Act…