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CCPA 2.0: The CPRA Is On The Ballot In California

For companies scrambling to button up their California Consumer Privacy Act (CCPA) compliance by the July 1 enforcement date, some news out of the state capital of Sacramento: Per a memorandum issued June 24, 2020 by the...more

CCPA Regulations: Are Vehicle ID Numbers Personal Information?

Commenters on the final California Consumer Privacy Act (CCPA) regulations asked if a Vehicle Identification Number, even by itself, is personal information. Do you have to delete it? How do you address sharing of VINs with...more

CCPA Regulations: ‘What Is Easy To Understand?’

A comment requested that the California Attorney General clarify the specific requirements for making privacy notices “easy to read and understandable to the average consumer” under the California Consumer Privacy Act...more

CCPA Regulations: What Is The Meaning Of Conspicuous?

Would conspicuous by any other name … link as effectively? Multiple comments to the final California Consumer Privacy Act regulations ask the California Attorney General to explain what “conspicuous link” means for the...more

CCPA Regulations: Does An Online Form Constitute Valid ‘Notice At Collection?’

A comment asks the California Attorney General if directing a consumer to an online form could constitute a valid notice at collection under the recently finalized California Consumer Privacy Act regulations. The Attorney...more

CCPA Regulations: IP Addresses And Residence, Backup And Archive Systems, Opt-Outs And Third Parties

More responses from the California Attorney General to questions about the final California Consumer Privacy Act regulations: Q. Can a business use an IP address to determine if a website visitor is a California...more

CCPA Regulations: ‘Opt Out’ Links, Deletion of Personal Information, IP Addresses

The California Attorney General has addressed a wide range of questions from businesses and other interested parties, in responding to comments to final California Consumer Privacy Act (CCPA) regulations. Here are three...more

California AG Suggests Additional CCPA Regulations May Be Needed

In the detailed summaries of comments to the final California Consumer Privacy Act (CCPA) regulations, responses from the California Office of the Attorney General indicate that some areas and issues flagged in the comments...more

CCPA Regulations: Explaining Consumer Rights In The Privacy Notice

Exactly which consumer rights need to be explained in a privacy notice? The California Attorney General recently addressed this question in responding to comments to final California Consumer Privacy Act (CCPA)...more

Key Data Privacy Considerations For Vendor Management

Key takeaways from my recent presentation titled “Service Providers v. Data Processors: What Should Your Agreement Address?” with Lexology and Exterra...more

California AG Won’t Delay CCPA Enforcement, But May Exercise Prosecutorial Discretion

California’s Attorney General won’t delay enforcement of key provisions of the California Consumer Privacy Act, but will use prosecutorial discretion in enforcing them, according to its Final Statement of Reasons for the...more

The California AG’s CCPA Regulations Final Statement Of Reasons: Key Takeaways

California Attorney General Xavier Becerra has submitted a final California Consumer Privacy Act (CCPA) regulations package. The final version is essentially identical to version three of the regulations released in early...more

Prepare For The Final CCPA Countdown

California Attorney General Xavier Becerra submitted final proposed regulations under the California Consumer Privacy Act (CCPA) to the California Office of Administrative Law (OAL)...more

Senate Democrats Introduce A Second Federal COVID-19 Privacy Bill

Following on the heels of the COVID–19 Consumer Data Protection Act of 2020, a bill recently filed by Republican Senators, Democratic Sens. Richard Blumenthal and Mark Warner introduced the "Public Health Emergency Privacy...more

California AG Reminds Consumers Of Their Rights Under CCPA During COVID-19 Pandemic

California Attorney General Xavier Becerra issued an alert reminding consumers of their data privacy rights amid the COVID-19 public health emergency. This included a specific reference to CCPA and the rights granted under...more

California AG Releases Third Draft Of CCPA Regulations

The California Attorney General has published a third draft of the California Consumer Privacy Act regulations- Key takeaways: Removes example indicating IP addresses may not be personal information in certain...more

California Attorney General Issues Amended CCPA Regulations For Comment

The California Office of the Attorney General has published proposed amendments to the California Consumer Privacy Act (CCPA) draft regulations. The amendments are open for public comment until 5 pm PT on Feb. 24, 2020....more

Top Ten Things EU Companies Should Consider In Light Of CCPA

1.Yes, CCPA can apply to you even if you have no physical presence in California. 2.Yes, if you have done some GDPR compliance you are in better shape for CCPA. 3.No, your GDPR compliance work is NOT sufficient for CCPA...more

CCPA Compliance Principles CMOs Need To Keep In Mind

The California Consumer Privacy Act has significant implications for Chief Marketing Officers. Here are some important principles CMOs should keep in mind when planning compliance efforts, included in my recent presentation...more

Key Points On CCPA For Employers

Here are some key points for employers to keep in mind related to the California Consumer Privacy Act (CCPA), which were included in my presentation to a recent meeting of Fox Rothschild’s Labor & Employment Practice...more

California Attorney General Issues Consumer Advisory On CCPA

“In California we are rebalancing the power dynamic by putting power back in the hands of consumers. I encourage all Californians to take a moment to understand their new rights and exercise these rights to take control of...more

CA Senate Proposes Expanded CCPA Carve-Outs Related To HIPAA, Biomedical Research

On the sixth day of CCPA the California Senate Health Committee gave to me … a HIPAA carve-out. AB 713, reported favorably by the California Senate Health Committee, would expand the exemption related to HIPAA and medical...more

Digital Advertising Alliance’s CCPA Opt Out Tools Launch January 1

The Digital Advertising Alliance (DAA) announced that its web- and app-based tools are expected to go live on Jan. 1, 2020, as the California Consumer Privacy Act (CCPA) takes effect. The web-based tool will enable...more

California AG Releases Title And Summary Of CCPA 2.0 Ballot Measure

California Attorney General Xavier Becerra released the title and summary for the CCPA 2.0 ballot initiative, the California Privacy Rights Act....more

CCPA 2.0: What’s New In The Revised CPRA Proposal

Alastair Mactaggart, the proponent of the "CCPA 2.0" ballot initiative in California, has submitted to the Office of the Attorney General a revised version of the proposed "California Privacy Rights Act" (CPRA) that he hopes...more

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