The California Privacy Rights Act (CPRA) that amended California’s Consumer Privacy Act (CPPA) comes fully into force on January 1, 2023 and the California Privacy Protection Agency is supposed to start enforcing the CPRA on July 1, 2023.  

Covered employers should spend sufficient time at the end of 2022 to prepare for compliance. Attached is a sample template Notice that employers may review to help move that process forward.  Please note that any notice should be customized for an employer’s specific business and there is no “one size fits all” notice provision.

So, employers covered by the CPRA/CPPA should work with counsel to customize a unique notice to ensure that proper notice is provided to their California workforce and applicants. A “data mapping” exercise may be warranted to identify the full range of Personal Information or Sensitive Personal Information that the Company maintained, for which purposes and how long such information is maintained so that a company’s policies adequately and accurately reflect the correct information. This, too, may be developed with counsel to best protect a California employer.