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Understanding Breach Notification Obligations Under California Law: What Does the CCPA Require? - Dear Mary – Incidents +...

‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more

California AG Announces Second CCPA Settlement, Asserting DoorDash Failed to Deliver Privacy (UPDATE)

In a recent alert, we reported that California Attorney General (AG) Rob Bonta announced a settlement with DoorDash over allegations that the company violated the California Consumer Privacy Act (CCPA) and the California...more

California AG Announces Second CCPA Settlement, Asserting DoorDash Failed to Deliver Privacy

In the second settlement under the California Consumer Privacy Act (CCPA), California Attorney General (AG) Rob Bonta announced a settlement over allegations that DoorDash sold consumers' personal information in a manner that...more

Silver Lining for Cos. in Proposed Calif. Privacy Law Changes

On Oct. 17 and again on Nov. 3, the California Privacy Protection Agency, or CPPA, modified the text of the proposed regulations implementing the California Privacy Rights Act, or CPRA. Originally published in Law360 on...more

CCPA/CPRA Will Apply to Employee AND B2B Data — Five Steps to Prepare for the January 1, 2023 Effective Date

Exemption Extensions Failed. On August 31, California's legislature ended its 2022 session without adopting legislation to extend the California Consumer Privacy Act (CCPA) employee and business-to-business (B2B) personal...more

Not So Pretty: Top Takeaways From First CCPA Settlement With Sephora and Updated Enforcement Case Examples

With the notice and cure set to expire on January 1, 2023, California Attorney General Rob Bonta (CA AG) provided a glimpse at what to expect with its first settlement of alleged violations of the California Consumer Privacy...more

California Privacy Protection Agency Publishes Draft Rules

The California Privacy Rights Act (CPRA) established the California Privacy Protection Agency (CPPA), and requires the CPPA to adopt, amend, and rescind regulations on 22 topics — including, among other things, definitions,...more

CPRA Series: Part Four – Data Processing Obligation

The California Privacy Rights Action (CPRA) will significantly impact how entities process personal information requiring covered businesses to review and update their existing vendor agreements. The CPRA also includes...more

CPRA Series: Part Two – Consumer Rights

Most privacy laws derive from the same core foundational principles, namely the Fair Information Practice Principles (FIPPs). This includes the California Consumer Privacy Act of 2018 (CCPA), California Privacy Rights Act of...more

Continued Wait Time for CPRA Regulations

California Privacy Protection Agency Director Ashkan Soltani recently announced that long-awaited regulations related to the California Privacy Rights Act (CPRA) would be delayed. The agency initially scheduled a July 1...more

California Lawmakers Propose Two Bills to Exempt Employee and B2B Data From Scope of CPRA

On February 18, California lawmakers proposed two bills that further extend the existing employee and business-to-business (B2B) data exemptions included in the California Consumer Privacy Act and the California Privacy...more

California AG Issues CCPA Notices to Businesses Operating Loyalty Programs

On January 28, California Attorney General Rob Bonta announced that his office was beginning an “investigative sweep” of businesses operating consumer loyalty programs in California. The California AG’s press release stated...more

California Privacy Protection Agency Begins to Take Shape

The California Privacy Protection Agency (CPPA) is the first state privacy agency in the nation and was created as part of the California Privacy Rights Act (CPRA). While this agency has already been formed, it will not begin...more

Litigation and Enforcement: Virginia Consumer Data Protection Act Series (Part Five)

Like the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA), the Virginia Consumer Data Protection Act (VCDPA) does not grant a private right of action for alleged violations...more

California Court Tosses Alleged "Data Breach" Suit, Holding CCPA Does Not Apply Retroactively

In Gardiner v. Walmart, Inc., a Walmart customer who purchased goods online filed a putative class action alleging that Walmart's cybersecurity procedures led to a purported unauthorized disclosure of his personal identifying...more

Notice and Disclosure Obligations: Virginia Consumer Data Protection Act Series (Part Three)

One key area where Virginia’s Consumer Data Protection Act (CDPA) differs from the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) is the law’s notice and disclosure...more

California AG Releases Third Set of Proposed Modifications to CCPA Regulations

On October 12, less than a month before California will vote on a referendum that would significantly overhaul the California Consumer Privacy Act (CCPA), the California attorney general released a third set of Proposed...more

California Consumer Privacy Act Enforcement Series: OAG’s Reaction to CPRA Referendum

CCPA 2.0: A Refresher - Just as the dust from the CCPA began to settle, on June 24, 2020, the California Secretary of State released a memorandum stating that the California Privacy Rights Act (the “CPRA”), also known as...more

The CCPA Regulations Have Been Approved and Are Effective Immediately

On August 14, 2020, the final regulations for the California Consumer Privacy Act (CCPA) (available here) were approved by the California Office of Administrative Law (OAL) and are effective immediately. The CCPA has...more

California Consumer Privacy Act Enforcement Series: Failing to Provide Adequate Notice at Collection

Enforcement of the California Consumer Privacy Act (CCPA) began July 1, 2020. Our privacy team at Troutman Pepper includes several attorneys who worked in an attorney general’s office. This privacy regulatory team has...more

California Consumer Privacy Act Enforcement Series: Service Providers

Enforcement of the California Consumer Privacy Act (CCPA) began July 1, 2020. Our privacy team at Troutman Pepper includes several attorneys who worked in an attorney general’s office. This privacy regulatory team has...more

California Consumer Privacy Act Enforcement Series: Treating the CCPA Like a Check-the-Box Exercise

Enforcement of the California Consumer Privacy Act (CCPA) began July 1, 2020. Our privacy team at Troutman Pepper includes several attorneys who worked in an attorney general’s office. This privacy regulatory team has...more

California Consumer Privacy Act Enforcement Series: The Infamous “Do-Not-Sell” Button

Enforcement of the California Consumer Privacy Act (CCPA) began July 1, 2020. Our privacy team at Troutman Pepper includes several attorneys who worked in an attorney general’s office. This privacy regulatory team has...more

CCPA Enforcement Area No. 1 - The Infamous "Do-Not-Sell" Button

Enforcement of the California Consumer Privacy Act (CCPA) began July 1, 2020. Our privacy team at Troutman Pepper includes several attorneys who worked in an attorney general’s office. This privacy regulatory team has...more

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