As we previously covered in a post earlier this month, the California Privacy Protection Agency (“CPPA”) has published draft regulations on risk assessments and cybersecurity audits required by the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). On September 8, the CPPA held a public board meeting that included discussion of select portions of the regulations. Prior to the meeting, the board circulated copies of the draft regulations for…
Special thanks to our Baker McKenzie speakers Danielle Benecke and Ben Allgrove, and Industry Experts Ashley Pantuliano, Associate General Counsel, OpenAI, Julian Tsisin, Global Legal & Compliance Technology, Meta, Janel Thamkul, Deputy General Counsel, Anthropic, and Suneil Thomas, Managing Counsel, Google Cloud AI. Baker McKenzie is pleased to invite you to an afternoon exploring the legal ramifications of the AI Revolution on October 10. Following an interactive keynote discussion with our in-house panelists, leading Baker McKenzie AI lawyers will address the cutting edge legal and regulatory…
On September 6, 2023, California Governor, Gavin Newson, issued an executive order to study the development, use, and risks of generative artificial intelligence (“Gen AI”). Similar to data privacy, California is the first state to analyze Gen AI under this lens. Under the executive order, state agencies will be required to perform risk assessments, create ethical guidelines for Gen AI usage and formulate new policies and regulations. Goals of the executive order are to (i)…
On August 29, 2023, the California Privacy Protection Agency (“CPPA”) published draft regulations on risk assessments and cybersecurity audits required by the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). The CPPA will discuss the draft regulations at the upcoming public meeting on September 8, 2023. The draft regulations make clear that the CPPA has not yet begun formal rulemaking, and that the draft regulations are “intended to facilitate…
If you are a data broker or a business that relies on data brokers for targeted advertising, you should be aware that the California Data Broker Law may be significantly changed under a proposed bill. Under Senate Bill 362, the California Privacy Protection Agency (CPPA) would be required to set up, by January 1, 2026, an accessible deletion mechanism where consumers could request deletion via the CPPA that all data brokers then have to honor.…
Just a few weeks after California Attorney General Bonta announced an investigative sweep through inquiry letters sent to California employers, today the California Privacy Protection Agency (CPPA) announced a California Consumer Privacy Act (CCPA) review of data privacy practices by connected vehicle manufacturers and related technologies, focusing on embedded features including “location sharing, web-based entertainment, smartphone integration, and cameras,” because “vehicles often automatically gather consumers’ locations, personal preferences, and details about their daily lives.” In…
So far this year, three US states have passed laws with specific obligations related to consumer health privacy law: Washington, Connecticut, and Nevada. When it comes to California, the omnibus California Consumer Privacy Act (CCPA) applies also to the processing of health information. But, if the sectoral Confidentiality of Medical Information Act (CMIA) applies and is complied with, CMIA, and not the CCPA, applies. Most companies that do business in California are subject to CMIA,…
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.…