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Pressure-Testing Your Privacy Program for 2025

With the onslaught of new privacy, AI and cyber legislation coupled with promises for enforcement and class action litigation, running a well-functioning and flexible privacy and cyber program is increasingly a critical...more

Navigating Consumer Opt-Outs in Corporate Transactions: Insights on California’s AB 1824

On September 29, 2024, California Governor Gavin Newsom signed AB 1824  into law, amending the California Consumer Privacy Act (CCPA) to require entities involved in corporate transactions, such as mergers and acquisitions,...more

California's Delete Act: A First of Its Kind Data Broker Law

On October 10, 2023, California Governor Gavin Newsom signed SB 362 into law. The “Delete Act” is intended to bridge a gap in consumer privacy rights – whereas the California Privacy Rights Act (the CPRA) grants consumers the...more

The Future of Insurance - Colorado’s New ECDIS and AI Model Regulations

On September 21, 2023, the Colorado Division of Insurance adopted a Final Regulation implementing S.B. 21-169, the 2021 law governing Colorado-licensed insurers’ use of external consumer data and information sources (ECDIS),...more

Colorado Privacy Act - Enforcement is here

The Colorado Privacy Act (“CPA”), Colorado’s first comprehensive consumer privacy law, came into effect on July 1, 2023.  Like many new privacy laws, though, there has been uncertainty surrounding when meaningful enforcement...more

Expansion of Connecticut Data Privacy Act

As with a growing number of states, Connecticut passed a comprehensive consumer privacy law, the Connecticut Data Privacy Act (the “CTDPA”), on May 10, 2022. The CTDPA becomes effective on July 1, 2023 and, in spite of the...more

Colorado’s “Loyalty Program” regulations are final, and they blow California’s rules out of the water

On March 15, 2023, the Colorado Attorney General’s Office announced the finalization of the Regulations implementing the Colorado Privacy Act (CPA), which will take effect on July 1, 2023. Covered businesses that make use of...more

Enforcement is Coming - Are your Privacy Policy and Cookies Solution Ready?

On January 1, 2023, the California Privacy Rights Act of 2020, which amended the existing California Consumer Privacy Act (collectively, the “CPRA”) and Virginia’s Consumer Data Protection Act (“VCDPA”) went into effect....more

Global Privacy Signaling: The Trendsetting Opt-Out Mechanism

By now, it is generally known that comprehensive privacy laws include requirements to allow consumers to opt-out of the sale of the their personal information, including personal information collected through the use of...more

Data Privacy FAQ's: How do cure periods work under the new state privacy laws?

Do Companies have a cure period for alleged violations under the California Privacy Rights Act (“CPRA”)? No, the CPRA eliminates the thirty (30) day cure period originally permitted under the California Consumer Privacy...more

Colorado Privacy Act Signed into Law

On July 7, 2021, Governor Jared Polis officially signed the Colorado Privacy Act (“CPA”) into law, after the bill had passed both the Colorado House and Senate in June. The effective date of the CPA is July 1, 2023....more

CPRA Digest - New Consumer Rights under CPRA and What That Means for Your Business

On November 3, 2020, Californians voted to pass Proposition 24, expanding and modifying the California Consumer Privacy Act (“CCPA”), which came into force on January 1, 2020. The new California Privacy Rights Act (“CPRA”)...more

The CPRA Digest: Data Minimization

On November 3, 2020, Californians voted to pass Proposition 24, expanding and modifying the California Consumer Privacy Act (“CCPA”), which came into force on January 1, 2020. The new California Privacy Rights Act (“CPRA”),...more

If a business receives a right to be forgotten request from an employee, or a former employee, does it have to delete the...

Not necessarily. As an initial matter, employees that are residents of California will not qualify as full “consumers” under the law until January 1, 2021....more

Can a company charge a fee for responding to a right to be forgotten request?

Likely no. Neither the CCPA nor the proposed regulations explicitly address the issue of imposing fees or costs on consumers for responding to requests for access or requests for deletion.  However, the CCPA does prohibit...more

CCPA 2020: Answers to the Most Frequently Asked Questions Concerning Cookies and AdTech

When the CCPA was enacted last year, BCLP published a Practical Guide to help companies reduce the requirements of the Act into practice. Following publication of the Guide, we wrote a series of articles that addressed...more

If a Company receives a request for deletion request under the CCPA, can it ask the consumer to confirm what information should be...

Yes. In fact, businesses may be required to obtain such confirmation from verified consumers under the current (non-final) regulations. As an initial matter, the CCPA states only that a business may have to delete the...more

CCPA Privacy FAQs: What is the statutory penalty for violation of the CCPA where there is no private right of action?

$2,500 for each violation and $7,500 for each intentional violation. The CCPA only provides a private right of action to any consumer whose unencrypted sensitive-category information has been breached as a result of a...more

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