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CCPA Amendments Extend Protections to Reproductive Health and Citizenship Status

Governor Newson recently signed two amendments to the CCPA strengthening protections for certain data types. The changes go into effect January 1, 2024....more

The Comprehensive Privacy Law Deluge: Impact on Loyalty Programs

Among the various requirements under US state comprehensive privacy laws, those that relate to loyalty programs may be some of the most confusing. Only three states — California, Colorado and Florida — regulate these...more

What Do the CPPA’s Draft Regulations on Risk Assessments and Cybersecurity Audits Mean for Companies?

The CPPA, the California regulatory body charged with enforcing CCPA, has now issued draft regulations on risk assessments and cybersecurity audits. The draft was released ahead of a public board meeting to discuss those...more

Impact of the Last Minute CCPA-Enforcement Delay

A California court recently issued a ruling delaying the CPPA’s ability to enforce the most recent CCPA regulations until March 29, 2024. This does not delay enforcement of the CCPA statute or existing regulations....more

CPRA Update: Moving Toward Finalization

The California Privacy Protection Agency (CPPA) Board recently met and unanimously voted to finalize the proposed final CPRA regulations. This approved version was first released in January and updated those released in...more

IAB Steps In State Signal Morass

Companies who participate in the AdTech and digital advertising eco-system are very familiar with the Interactive Advertising Bureau and its form advertiser agreements. Those agreements can help streamline negotiations,...more

Comparing and Contrasting the Opt Out Preference Signal Across States

The talk of “opt-out preference signals” or global privacy controls (GPC) has been increasing as companies dig into the forthcoming requirements under US “comprehensive” privacy laws. What is an opt-out preference signal? An...more

State Comprehensive Privacy Laws: Status of the Regulations

With 2023 quickly approaching, many are spending this final quarter preparing for the five US state “comprehensive” privacy laws. Some of these contemplate clarifying regulations with technical and operational requirements....more

CCPA May Soon Apply to Employee and B2B Information

Companies subject to California’s Consumer Privacy Act (CCPA) may soon need to figure out how to scale their privacy compliance programs to include employee and B2B information. The current exemptions that exist for most of...more

What Should We Do About the Draft CPRA Regulations?: Collection and Notice

The California Privacy Protection Agency (CPPA) recently released the draft proposed CCPA Regulations and draft initial statement of reasons. Importantly, these are draft regulations that are likely to be subject to extensive...more

Connecticut Fifth State to Pass a Comprehensive Privacy Law

Connecticut just joined California, Colorado, Utah, and Virginia in passing a comprehensive privacy law. The Connecticut Data Privacy Act (CTDPA) goes into effect July 1, 2023, the same time as Colorado’s very similar law...more

In First CCPA “Opinion”, California AG Clarifies Scope of Access Requests

The California AG recently issued an opinion interpreting the scope of information that should be provided to consumers in an access request. In responding to access requests, companies must provide a list of all personal...more

California Broadens Security and Breach Laws, Includes Genetic Data

California recently updated both its data security and breach notice laws to include genetic data. With the passage of AB 825, the data security law now includes in the definition of “personal information” genetic data. The...more

California Enacts New Privacy Law for Genetic Data

California’s governor recently signed SB 41 into law. The bill enacts the Genetic Information Privacy Act (GIPA). The governor rejected a similar bill last year over concerns about COVID-19 public health efforts. To address...more

California Bill Clarifies Timing for CPRA Rulemaking Authority

California recently passed AB 694, which makes a few “technical” changes to the California Privacy Rights Act (CPRA). Importantly, this amendment clarifies the timing for the new California Privacy Protection Agency’s (CPPA)...more

California’s New Privacy Agency Seeks Feedback on CPRA

California’s new privacy protection agency recently issued an invitation for public comments as part of its preliminary rulemaking activities for the California Privacy Rights Act (CPRA). Introduced and passed by ballot...more

Breach of PHI? California AG Reminds Companies of Potential State Notification Obligations

The California AG recently reminded companies in the healthcare industry of potential data breach notification obligations beyond HIPAA. As ransomware attacks continue to rise, particularly in healthcare, companies should...more

The CCPA Wheels Keep Turning: The Addition of CPRA

By ballot initiative, California residents recently approved Proposition 24, or the California Privacy Rights Act (CPRA), with approximately 56 percent voting in favor. CPRA significantly amends the CCPA by expanding...more

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