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Complimentary Webinar – Understand and Prepare for the California Privacy Rights Act

Join us on January 21, 2021 at 12pm EST/9am PST for a complimentary webinar – Understand and Prepare for the California Privacy Rights Act. Panelists Elliot Golding, Glenn Brown and Lydia de la Torre of our Data Privacy & Cybersecurity Practice will provide an overview of the CPRA and its interplay with the CCPA.  The … Continue Reading

California Attorney General Proposes Minor Modifications to the CCPA Regulations

On December 10, 2020, the California Attorney General (“AG”) proposed some minor modifications  to the regulations implementing the California Consumer Privacy Act of 2018 (“CCPA”). The modifications were published in response to comments received by the AG following publication of the previous set of proposed modifications on October 12, 2020. Specifically, the new changes: Propose … Continue Reading

CCPA Amended to Address HIPAA Exemption, Deidentified Data Rules

Last month California Governor Gavin Newsom signed AB 713 into law, which more closely aligns CCPA to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other laws governing scientific research. Although these changes may help ease compliance challenges for the health care and life sciences industries, the changes only exempt from the … Continue Reading

More Proposed CCPA Regulations, but Without Significant Changes

The California Attorney General (“AG”) proposed changes to the California Consumer Privacy Act (“CCPA”) regulations on October 12, 2020.  Many of the proposed changes align with provisions that the AG withdrew over the summer during the California Office of Administrative Law (“OAL”) approval process.  Although most businesses likely won’t need to materially alter current business … Continue Reading

CCPA Business-to-Business and Personnel Carve-Out Extension Clears California Legislature

Following a winding path in the California Legislature, AB-1281 passed the CA Senate on Friday, August 28th, and the Assembly on Sunday, August 30th, and will now go to Governor Newsom for his signature. Governor Newson is not expected to veto the bill. AB-1281 amends the California Consumer Privacy Act (CCPA), extending the business-to-business and … Continue Reading

Final CCPA Regulations Are Now in Effect – With a Few Changes

The California Attorney General (“AG”) announced on Friday, August 14th, that the Office of Administrative Law (“OAL”) approved the final California Consumer Privacy Act (“CCPA”) regulations. The AG submitted the regulations to OAL for approval on June 1, 2020.  The final version includes several substantive changes where the AG “withdrew” provisions along with procedural and … Continue Reading

Amendments to CA AB-1281: Addition by Subtraction?

In a surprising turn of events, the California State Senate significantly amended California Assembly Bill 1281 (“AB-1281”) late last week.  AB-1281 initially proposed enhanced protections for the use of facial recognition technologies, which have now been removed.  The amended AB-1281 now focuses on extending by one year the B2B and employee exemptions provided for under … Continue Reading

CCPA Enforcement Begins Today

As of today, July 1, 2020, the California Attorney General (“AG”) will begin enforcing the California Consumer Privacy Act of 2018 (“CCPA”), which went into effect on January 1, 2020.  Under the CCPA, the AG may recover civil penalties of up to $2,500 for each violation and up to $7,500 for each intentional violation.  The … Continue Reading

California Attorney General Submits Final Proposed Regulations and Accompanying Materials

After months of waiting, on June 1, 2020, the California Office of the Attorney General (“AG”) unveiled the final proposed California Consumer Privacy Act (“CCPA”) regulations, which are unchanged from the last version circulated in early March 2020 (summarized here).  The AG also published extensive materials, including more than 500 pages of responses to public … Continue Reading

CPRA Proponents Submit Over 900,000 Signatures for Ballot Initiative

On Monday, May 4, 2020, Californians for Consumer Privacy – the organization behind the ballot initiative that was the genesis of the California Consumer Privacy Act of 2018 (CCPA) – announced that it is submitting signatures to qualify the California Privacy Rights Act (CPRA) for the November 2020 ballot. According to the announcement, “well over … Continue Reading

CCPA Enforcement Still Imminent; Temporary Exemptions May Lapse

Despite the request for a delay in the enforcement of the California Consumer Privacy Act of 2018 (CCPA) made by five leading advertising and marketing trade associations, it appears CCPA enforcement will continue as planned.  As evidence of this, the California Attorney General recently issued a press release reminding Californians of their rights and businesses’ … Continue Reading

California Attorney General Proposes Further Modifications to Proposed CCPA Regulations

On March 11, 2020, the California Attorney General (“AG”) published a second round of modifications to the proposed regulations under the California Consumer Privacy Act of 2018 (“CCPA”). The AG initially published the proposed regulations in October 2019 and then published modifications to such proposed regulations in February 2020. The deadline for submitting comments on … Continue Reading

California Attorney General Proposes Modifications to the Proposed CCPA Regulations

On February 7, 2020, the California Attorney General (AG) announced changes to the California Consumer Privacy Act of 2018 (CCPA) proposed regulations. The AG updated its announcement on February 10, 2020, to indicate that an additional provision was being modified. The modifications include changes to the “Right to Opt Out,” the permissible uses of data … Continue Reading

CCPA: Data Brokers Must Register Now

When A.B. 1202 was signed into law last fall, it was expected that the data broker registration requirement would not go into effect until 2021. However, the California Attorney General’s Office has taken the position that organizations that qualify as data brokers must register on or before January 31, 2020. Our Client Alert on this … Continue Reading

CCPA Coming Soon… Is Your Organization Ready?

In just a few short weeks (January 1, 2020), the California Consumer Privacy Act (CCPA) will impose burdensome GDPR-like transparency and individual rights requirements on almost every company that handles “personal information” regarding California residents, including employees.  Is your organization ready? We have prepared a number of client alerts and blog posts to help you … Continue Reading

ABA Hosts CCPA Webinar

On December 4, 2019, Squire Patton Boggs partner, Elliot Golding and colleagues Joanne Charles (Microsoft) and Courtney Manzel (Volkswagen Group of America) will present a webinar – The Final California Consumer Privacy Act: What Are Your Obligations?  The webinar will address: Scope and applicability (e.g., what companies, data and processes will be impacted); Key requirements … Continue Reading

I’m a Financial Institution – What Do I Need to Do Under the CCPA?

This post is part of our series highlighting key compliance issues under the California Consumer Privacy Act (CCPA). For a broader look at the CCPA, please see prior posts from members of our Data Privacy & Cybersecurity  regarding applicability, gap assessments, and the recent amendments. Stay tuned for further posts in this series. Introduction Since the … Continue Reading

Proposed CCPA Regulations: Initial Overview and Highlights

On October 10, 2019, the California Attorney General (California AG) issued the long-awaited California Consumer Privacy Act (CCPA) Regulations (Proposed Regulations), along with an Initial Statement of Reasons (ISOR) explaining the Proposed Regulations. These Proposed Regulations not only fill in statutory gaps, but also create several substantive new requirements. Companies may submit comments through December … Continue Reading

I’m an Employer – What Do I Need to Do under CCPA?

Welcome to our post highlighting key compliance issues under the California Consumer Privacy Act (CCPA). For a broader look at CCPA, please read our prior posts regarding applicability, gap assessments, and the recent amendments, and remember to register for our upcoming webinar covering the final requirements of the law on October 17, 2019. Stay tuned … Continue Reading

Déjà Vu:  New California Ballot Initiative Seeks to Strengthen Data Privacy Further

Even though the California Consumer Privacy Act (“CCPA”), enacted in June 2018, radically transformed data privacy regulation in the US, it appears that some privacy advocates in California are seeking to strengthen consumers’ data privacy rights even further.  Californians for Consumers Privacy, the group behind the ballot initiative that led to the CCPA, announced this … Continue Reading
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