The California Attorney General’s office (OAG) recently released a third set of proposed modifications to the California Consumer Privacy Act (CCPA) regulations. This comes on the heels of the second set of modifications the Office of Administrative Law (OAL) approved just two months ago (see article here). The third set of proposed modifications restores certain provisions the OAG had previously withdrawn from its draft regulations submitted to the OAL in July, as well as clarifies and adds illustrative examples to some provisions. Overall, the modifications do not significantly alter the CCPA regulatory landscape, and if accepted, are not likely to impact businesses greatly. Nonetheless, businesses should review the changes, which address the following topics, to confirm that they would not require any adjustment in business practice:
Continue Reading California AG Proposes Third Amended Regulations to CCPA
California AG Submits Final Proposed CCPA Regulations to the Office of Administrative Law in Final Step to Effectiveness of the Regulations
On June 1, 2020, the Office of the California Attorney General submitted its final proposed CCPA regulations to the California Office of Administrative Law (OAL) to review for compliance with the California Administrative Procedures Act. The text of the final proposed regulations is the same as the second set of modifications, released on March 11 and summarized here. Accompanying the proposed regulations is a Statement of Reasons setting out modifications from the initial proposed text of the regulations published on October 11, 2019. If the regulations are approved by OAL, the final text will be filed with the California Secretary of State and will become enforceable. The core provisions of the CCPA became operational on January 1, 2020, and the AG may bring enforcement actions under the CCPA as of July 1, 2020, although it could not premise enforcement actions on its regulations until they are final.
Continue Reading California AG Submits Final Proposed CCPA Regulations to the Office of Administrative Law in Final Step to Effectiveness of the Regulations