With the enactment of the European General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act ("CCPA”), companies have been forced to cope with a shifting privacy landscape that impacts the data that they collect online and offline from customers, visitors, and employees. In the context of the CCPA, poor drafting, combined with a lack of practical regulatory guidance and the prospect of imminent judicial challenges, make it a particularly difficult statute for compliance.
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