News & Analysis as of September 6, 2025

Audits

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California Finalizes New CCPA Regulations: What Businesses Need to Know

Foley Hoag LLP - Security, Privacy and the... on 8/29/2025

California continues to lead the way in data privacy standards as the latest regulatory updates from the California Privacy Protection Agency (“CPPA”) mark a significant step forward in safeguarding individual rights and data...more

The CPPA Finalizes Rules on ADMT, Risk Assessments, and Cybersecurity Audits

Baker Botts L.L.P. on 8/14/2025

On 24 July 2025, the California Privacy Protection Agency (CPPA) unanimously approved a long-awaited and -debated rulemaking package that addresses: (i) the use of automated decision-making technology, (ii) mandatory risk...more

California Finalizes Groundbreaking Regulations on AI, Risk Assessments, and Cybersecurity, Part II: What Businesses Need to Know

Ogletree, Deakins, Nash, Smoak & Stewart,... on 8/8/2025

In July 2025, the California Privacy Protection Agency (CPPA) Board unanimously approved new regulations pursuant to the California Consumer Privacy Act (CCPA) that specifically address the use of automated decisionmaking...more

Legal Update: New Updates to CCPA Regulations: California’s Focus on ADMT, Cybersecurity Audits, Risk Assessments, and More

Robinson & Cole LLP on 8/7/2025

On July 24, 2025, the California Privacy Protection Agency (CPPA) Board unanimously approved amendments to the California Consumer Privacy Act (CCPA). These substantial changes include new compliance obligations for...more

California Finalizes CCPA Regulations on Cybersecurity Audits, Risk Assessments, and Automated Decisionmaking: Key Provisions and...

Blank Rome LLP on 8/6/2025

The California Privacy Protection Agency (“CPPA”) finalized a set of regulations under the California Consumer Privacy Act (“CCPA”) on July 24, 2025, that address cybersecurity audits, risk assessments, and automated...more

CPPA Board Finalizes New Rules on ADMT, Cybersecurity Audits, and Risk Assessments

Morgan Lewis on 8/5/2025

The California Privacy Protection Agency (CPPA) board unanimously voted on July 24, 2025 to finalize a package of regulations related to automated decision-making technology (ADMT), cybersecurity audits, and risk assessments....more

Independent Cybersecurity Audits Will Be Required for ‘Significant Risk’ Under CCPA

Herbert Smith Freehills Kramer on 8/4/2025

The California Privacy Protection Agency (CPPA) has unanimously adopted new regulations requiring certain businesses subject to the California Consumer Privacy Act (CCPA) to conduct annual audits of their cybersecurity...more

CPPA releases updated regulations proposed after comment period

Orrick, Herrington & Sutcliffe LLP on 8/4/2025

On July 24, the CPPA released updated regulations under the California Consumer Privacy Act, (CCPA) establishing those changes made after the 45-day comment period affecting three main areas of concern: Automated...more

California’s New Privacy and Cybersecurity Regulations on Risk Assessments, Automated Decision making and Cybersecurity Audits:...

Goodwin on 8/1/2025

During a Board Meeting on July 24, 2025, the California Privacy Protection Agency (CPPA) unanimously approved the long-awaited final text of its second rulemaking package, implementing a broad swath of new requirements...more

CPPA Approves New CCPA Regulations on AI, Cybersecurity, and Risk Governance, and Advances Updated Data Broker Regulations

Wilson Sonsini Goodrich & Rosati on 8/1/2025

On July 24, 2025, the California Privacy Protection Agency (CPPA) Board voted to approve a long-awaited rulemaking package imposing substantial new compliance obligations on businesses subject to the California Consumer...more

The Intersection of Agentic AI and Emerging Legal Frameworks

Foley & Lardner LLP on 12/20/2024

The evolution of artificial intelligence (AI) has introduced systems capable of making autonomous decisions, known as agentic AI. While generative AI essentially “creates” – providing content such as text, images, etc. –...more

California Takes Steps to Regulate the Use of AI for Significant Employment Decisions

Proskauer - California Employment Law on 11/26/2024

On November 8, 2024, the California Privacy Protection Agency (CPPA) voted 4-1 to proceed with formal rulemaking regarding automated decision-making technology (“ADMT”), which the draft regulations define as “any technology...more

CPPA Declines to Advance New Draft CCPA Regulations

Paul Hastings LLP on 7/30/2024

The California Privacy Protection Agency (CPPA) Board met last week to discuss the latest updates on California Consumer Privacy Act (CCPA) draft regulations for cybersecurity audits, risk assessments, automated...more

Major Win for California Privacy Protection Agency: Enforcement of Regulations Can Begin Immediately

Mintz - Privacy & Cybersecurity Viewpoints on 2/16/2024

If you have been relying on last year’s court order staying the ability of the California Privacy Protection Agency (CPPA) to enforce regulations promulgated under the California Privacy Rights Act (CPRA) to also stay your...more

CPPA’s Regulatory Enforcement Restored: It’s Time to Get Compliant

Woods Rogers on 2/15/2024

For businesses subject to California Consumer Privacy Act (CCPA), privacy compliance just became urgent. A California appellate court agreed on February 9, 2024, with the California Privacy Protection Agency (CPPA) that there...more

California Privacy: A Deeper Dive Into the New Regulations Expected in 2024

Jones Day on 2/14/2024

The Background: The California Privacy Protection Agency board ("CPPA" or "Board") is in the process of issuing new regulations as authorized under the California Privacy Rights Act. These three sets of proposed regulations...more

California Advancing Regulations for AI, Other Cybersecurity Issues

Procopio, Cory, Hargreaves & Savitch LLP on 1/3/2024

California continues to push beyond other states in developing and implementing privacy and cybersecurity regulations. The latest evidence came from the recent release of draft regulations from the California Privacy...more

CPPA Publishes Additional Proposed Regulations - Including Proposed Revisions to CCPA Regulations - For Discussion at December...

WilmerHale on 12/7/2023

In the run-up to this Friday’s December Board meeting, the California Privacy Protection Agency (CPPA or the “Agency”) has continued its recent flurry of regulatory activity. Late last week, the CPPA published an additional...more

CPPA Considers Next Set of CPRA Regulations Covering Cybersecurity Audits and Risk Assessments

Seyfarth Shaw LLP on 12/6/2023

The California Privacy Protection Agency (“CPPA”) issued and discussed draft regulations on Cybersecurity Audits and Risk Assessments late in the summer. The CPPA Board plans to discuss the draft regulations at its upcoming...more

California Shares Draft Rules on Audits, Assessments, and Automated Decisionmaking

Shook, Hardy & Bacon L.L.P. on 12/5/2023

On November 27, California’s dedicated privacy law enforcement agency, the California Privacy Protection Agency (CPPA), released a draft of new rules covering automated decisionmaking (yes, they made “decisionmaking” one...more

CPPA Publishes Proposed Revisions to CCPA Regulations

Husch Blackwell LLP on 12/4/2023

Keypoint: The Agency proposed more revisions to the CCPA regulations for consideration at the December 8 board meeting. On December 1, 2023, the California Privacy Protection Agency (Agency) published proposed revisions to...more

CPPA Publishes Revised Cybersecurity Audit Regulations in Advance of Board Meeting

Alston & Bird on 11/29/2023

On December 8, 2023, the California Privacy Protection Agency (CPPA) will hold a board meeting seeking public comment on various privacy regulations. The meeting, which will take place on Zoom, will cover several topics...more

CPPA Publishes Revised Draft Cybersecurity Audit Regulations

Husch Blackwell LLP on 11/9/2023

Keypoint: The California Privacy Protection Agency continued its rulemaking efforts by releasing revised draft cybersecurity audit regulations although the Agency has yet to initiate the formal rulemaking process....more

A Potential Look Into the Future: California Issues First Draft of Cybersecurity Audit and Risk Assessment Regulations

Perkins Coie on 9/27/2023

The Board of the California Privacy Protection Agency (the CPPA) held its first meeting since July on Friday, September 8, 2023, and discussed the first public draft of cybersecurity audit regulations and risk assessment...more

California Privacy Protection Agency Publishes Draft Cybersecurity Audit and Risk Assessment Regulations, Discusses at Public...

WilmerHale on 9/19/2023

On Friday, September 8, the California Privacy Protection Agency (CPPA) held a public board meeting. The primary topic of discussion at this meeting was the Agency’s draft regulations on cybersecurity audits and risk...more

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