In 2018, the California Legislature adopted the California Consumer Privacy Act (CCPA) and became the first state to enact a comprehensive law designed to protect the privacy of consumers’ personal information. Businesses that are subject to the CCPA are required, among other things, to respond to consumers who wish to…
The California Attorney General’s Office has finalized additional regulations implementing the California Consumer Privacy Act of 2018 (the CCPA). The new regulations, found here, are the most recent in a series of regulations that build on the rules last adopted in August 2020. The new regulations have a number of…
Just as we were getting used to the California Consumer Privacy Act of 2018 (the “CCPA”), Californians voted to approve Proposition 24, the California Privacy Rights Enforcement Act of 2020 (the “CPRA”). For now, the CCPA is still with us – the CPRA becomes effective on January 1, 2023 –…
Many races and initiatives that California voters considered on November 3 are still undecided, but Proposition 24, the California Privacy Rights Act of 2020 (the “CPRA”) isn’t one of them. The California electorate approved Proposition 24 by a comfortable margin – 56% of Californians voted in favor. Like its predecessor…
On September 29, California Governor Gavin Newsom signed an amendment (AB 1281) that extends the California Consumer Privacy Act (CCPA) partial employee and business-to-business exemptions through December 31, 2021. The extended exemptions may provide some relief to businesses struggling to comply with changing local, state and federal COVID-19 requirements. Partial…
As a privacy and cybersecurity lawyer, I’m often asked by clients and potential clients about preparing a privacy policy – whether they need one, and how much it costs. And underlying the question is an assumption – privacy policies are really just formalities, and all they need to do is…
There’s no question that this is one of the most difficult times we have faced. The turnaround from nearly full employment to 3,000,000 new unemployment claims, the sequestration of two-thirds of the population, the closing of restaurants, entertainment venues, places of worship, mass furloughs and layoffs, the elimination of the…
Amended CCPA Regulations – Key Takeaways On February 7, 2020, the California Attorney General issued a second draft of the regulations implementing the California Consumer Privacy Act of 2018 (the “CCPA”). Interestingly, while the Attorney General had earlier stated that the final regulations would be substantially the same as the…
The FTC Speaks On January 6, 2020, the Director of the Federal Trade Commission’s (FTC) Consumer Protection Bureau published a blog post with changes to the FTC’s approach to its orders and settlements of data breach enforcement actions. One of the key elements of the report was a revision to…
CCPA: Hotel Loyalty Programs, Data Retention and the Brave New World of Privacy By Robert E. Braun This article first appeared in the Hotel Business Review and is reprinted with permission from www.HotelExecutive.com. The California Consumer Privacy Act (the “CCPA” or the “Act”) is a piece of consumer privacy legislation…