March 12, 2020
On Wednesday, March 11, 2020, the Office of the Attorney General of California released a second set of revisions to the proposed regulations implementing the California Consumer Privacy Act.
The modifications include a number of substantive changes to the proposals. Below are some of the most notable changes. This list is not exhaustive, and regulated businesses should consult the full text of the proposed rules with qualified counsel.
The Attorney General's Office is receiving comments on these changes until 5:00 p.m. California time on Friday, March 27, 2020, by email to PrivacyRegulations@doj.ca.gov, or by mail to:
Lisa B. Kim, Privacy Regulations Coordinator
California Office of the Attorney General
300 South Spring Street, First Floor
Los Angeles, CA 90013
It is not clear when the regulations will be finalized, and it is not clear whether the final regulations will provide for a delayed effective or enforcement date.
The CCPA became effective January 1, 2020. The Attorney General may not bring an enforcement action until July 1, 2020.
The CCPA provides California residents with certain rights with regard to their personal information and imposes related requirements on certain businesses in California. Regulated businesses should consult the current and complete text of the law and regulations alongside knowledgeable counsel. Significant exemptions may apply to financial services businesses.
Businesses can view these second revised proposed regulations here, with a redline of changes from the October 2019 proposal here. Businesses can also obtain more information about the CCPA and the proposed regulations on the Attorney General's website, available here.
Webb McArthur of Hudson Cook, LLP, provided this alert.