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…
As most (but not all) business know, the California Consumer Privacy Act of 2018 (the “Act” or “CCPA”) goes into effect January 1, 2020. It is estimated that more than 500,000 companies are subject to the CCPA, many of them smaller and mid-size businesses that may not have pre-existing robust…
Complying with the California Consumer Privacy Act in 5 (more or less) Not So Easy Steps Part 5 of a Series Consumer Rights: Deletion, Do Not Sell, Non-Discrimination The California Consumer Privacy Act obligates covered businesses to disclose the categories of personal information, the sources of personal information and uses…
Complying with the California Consumer Privacy Act in 5 (more or less) Not So Easy Steps: Part 4 of a Series Verified Requests for Data The CCPA is hurtling headlong toward implementation on January 1, 2020. The Act, which is likely to be amended, perhaps substantially, in the next sixty…
Ever since the California Consumer Privacy Act (the “CCPA”) was adopted in 2018, various constituencies have lobbied for revisions. While multiple proposals were considered in the California legislature, only a few have a chance for passage and enactment. Last month, the California Senate Judiciary Committee passed several amendments to the…
On August 5, 2019, Marriott International announced that it had taken a $126 million charge in the second quarter, primarily as a result of the data breach it announced in 2018. Coincidentally, on July 9, 2019, The United Kingdom’s Information Commissioner’s Office (ICO), which enforces the General Data Protection Regulation…
Complying with the California Consumer Privacy Act in 5 (more or less) Not So Easy Steps Part 3 of a Series The Privacy Policy This is the third in a series of articles on complying with the California Consumer Privacy Act (CCPA). The CCPA is estimated to directly impact more…
Complying with the California Consumer Privacy Act in 5 (more or less) Not So Easy Steps Part 2 of a Series What’s Next – the Breach Response Plan This is the second in a series of articles on complying with the California Consumer Privacy Act (CCPA). The CCPA is estimated…