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CCPA Update:  Agencies push ahead with enforcement as Superior Court delays new regulations

The California Privacy Protection Agency (CPPA) and California Office of Attorney General (OAG) are publicly pressing ahead with enforcement now that they have the authority to enforce the California Consumer Privacy Act...more

With July 1st in view, Google updates CCPA contract terms

Google updated its privacy terms earlier this month, shifting away from offering many of its advertising services on a “service provider” basis. With the change, Google states that its Customer Match, Audience Partner API,...more

New California Draft Privacy Regulations: How They Would Change Business Obligations and Enforcement Risk

On Friday May 27, 2022, the California Privacy Protection Agency (CPPA) Board announced its next public meeting will be on June 8, 2022. The announcement simply stated the date of the meeting, that there are “some discussion...more

California AG’s First CCPA Opinion Takes a Broad View of the Right to Access Inferences

In the first formal written opinion interpreting CCPA compliance obligations, California Attorney General Rob Bonta concludes that the CCPA grants consumers the right to know and access internally generated inferences that...more

Soltani Appointed as Inaugural California Privacy Protection Agency Executive Director

During last month’s California Privacy Protection Agency Board (CPPA) meeting, the only substantive agenda item, addressed in closed session, was a discussion of two key appointments: the first Executive Director and a Chief...more

CPRA Update: California Privacy Rulemaking Process Begins

On September 22, the California Privacy Protection Agency (CPPA) issued an invitation for public comments as part of its first “preliminary” rulemaking activities. Established by the California Privacy Rights Act (CPRA)...more

CCPA Update: California AG Releases List of Enforcement Actions 

The California Office of the Attorney General has published a list of recent CCPA enforcement examples on its website. Each example summarizes the AG’s allegation of noncompliance and the steps that the companies took to...more

CPRA Update: How to Prepare for Privacy Compliance as an Employer

Last year’s voter guide to California Proposition 24, the California Privacy Rights Act (CPRA), included a stark argument against enacting the privacy ballot initiative because it did not go far enough to protect employee...more

CPRA Update: CalPPA Gets Started with Inaugural Meeting and Agenda

Just a few months after California officials announced the nominations of the inaugural Board members of the California Privacy Protection Agency (“CalPPA”), the CalPPA released the agenda for its first board meeting on June...more

CPRA Update: What is a “Contractor?”

The California Privacy Rights Act (CPRA), effective January 1, 2023, adds “contractors” to the list of entities that a business may entrust with customer data. So what is a “contractor?” And how are “contractors” different...more

California Privacy Legislation Round-Up: Gov. Newsom Signs CCPA Employee Exemption Extension, Vetoes Others

Prior to the September 30 deadline to sign or veto legislation, California Governor Gavin Newsom recently took action on three bills related to data privacy. Bringing some potential certainty to the dynamic CCPA landscape,...more

CCPA Update: Final Regulations Submitted but No Changes from Prior Draft

On June 2, California Attorney General Xavier Becerra announced that he had submitted final CCPA regulations to the Office of Administrative Law (OAL) for review. The final regulations are substantively identical to the...more

The CCPA Non-Discrimination Right, Explained

The California Consumer Privacy Act (CCPA) provides consumers with a right to non-discrimination when they exercise other privacy rights guaranteed by the law, such as the right to access, delete, or opt out of the sale of...more

No Delay? What To Expect on CCPA Enforcement Timing

The CCPA grants the California Attorney General (AG) the authority to enforce the CCPA starting on July 1, 2020. Last month, the AG confirmed no intention to delay that enforcement date due to the COVID-19 pandemic, despite...more

CCPA Update: Attorney General Releases Third Draft of Proposed CCPA Regulations

On Wednesday, the California Attorney General (AG) released a third draft of proposed CCPA regulations for public comment. The draft contains a series of technical corrections, along with a handful of substantive incremental...more

CCPA Update: Data Broker Registry Now Live

The California Attorney General unveiled its data broker registry on Monday. On or before January 31st, companies qualifying as a “data broker” based on the prior year’s activities are required to register their name and...more

CCPA Implementation: An Early Map

The January 1, 2020 effective date of the California Consumer Privacy Act (CCPA) has come and gone, but questions about how to comply with the law show no hint of disappearing. As companies move past their efforts to comply...more

CCPA Update: AdTech Options to Avoid a “Sale” and What Google Has to Say About It

Last Monday, Google released its answer to the CCPA: a new “service provider” contract.  Given Google’s widely used advertising and analytics technologies, Google’s new contract has the potential to influence how website...more

CCPA Update: Prioritizing Compliance with Two Months Until the CCPA Takes Effect

In exactly two months, the California Consumer Privacy Act (CCPA) takes effect. Many businesses are devoting resources to timely comply, but between the late rollout of the Attorney General’s draft regulations, recent...more

CCPA Update: California Governor Signs Seven Amendments to the CCPA

On Friday, California Governor Gavin Newsom signed seven legislative proposals to amend the California Consumer Privacy Act (CCPA), marking the end of a nearly-yearlong process to make changes to the new privacy law before it...more

CCPA Update: California Attorney General Issues Draft Privacy Rules

On Thursday, California Attorney General Xavier Becerra released draft regulations implementing the California Consumer Privacy Act (CCPA). The regulations provide the first glimpse into how the Attorney General interprets...more

CCPA Update: Legislature Amends the CCPA to Exclude Employee Data, B2B Communications for One Year

Last week, the California legislature voted to send five amendments to the CCPA to the California governor’s desk. The amendments include a one-year exemption for access and deletion rights to employee data and B2B...more

CCPA Update: With Legislative Session to End Friday, CCPA Amendments Slated for Final Vote

This week marks the final opportunity for California lawmakers to amend the CCPA before the legislative session closes on Friday, September 13th. The legislative posture of the amendments changed last Friday, when the Senate...more

CCPA Update: California Senate Committee Approves Privacy Law Amendments

Amendments to the California Consumer Privacy Act (CCPA) continued to advance on Monday, as the California legislature returned from its summer recess. With just five weeks to go until the September 13th deadline for the...more

California Senate Committee Blesses Majority of CCPA Amendments

Seven amendments to the California Consumer Privacy Act (CCPA) are one step closer to becoming law after the California Senate Committee on the Judiciary voted to advance the legislation earlier this month....more

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