Conceptual image about how a laptop computer with internet open a virtual door to worldwide information sharing.Keypoint: Those hoping that the final CCPA regulations will clarify its requirements may be disappointed. 

According to an article in Bloomberg Law, California Attorney General Becerra does not anticipate his office making substantial changes to the regulations as proposed when it issues the final regulations.

The AG’s office published the proposed regulations on October 10, 2019. The AG’s office held public hearings on the proposed regulations in early December, and the deadline for written comments passed on December 6. In past reports, the AG’s office signaled that they will move swiftly to issue the final regulations.

The CCPA goes into effect on January 1, 2020, but the AG’s office cannot enforce the statute until July 1, 2020. Nonetheless, Attorney General Becerra told Bloomberg Law that enforcement actions can cover activities in the first six months of 2020.

Commentators pointed out numerous areas of ambiguity with the proposed regulations during the hearing and comment period. However, at this point, it is unclear how much the AG’s office will do to address those concerns. In the interim, best efforts should be made to comply with the proposed regulations by January 1. This will come as little comfort to businesses that are struggling with operationalizing the CCPA and regulations in light of its lack of specificity and clarity on numerous topics.

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Photo of David Stauss David Stauss

David is leader of Husch Blackwell’s national privacy and cybersecurity practice group. He routinely counsels clients on responding to data breaches, complying with privacy laws such as GDPR and the California Consumer Privacy Act, and complying with information security statutes. He also…

David is leader of Husch Blackwell’s national privacy and cybersecurity practice group. He routinely counsels clients on responding to data breaches, complying with privacy laws such as GDPR and the California Consumer Privacy Act, and complying with information security statutes. He also represents clients in data security-related litigation. David is certified by the International Association of Privacy Professionals as a Certified Information Privacy Professional (US), Certified Information Privacy Technologist, and Fellow of Information Privacy.

Photo of Bob Bowman Bob Bowman

Bob advises clients on a range of intellectual property issues and keeps them current on emerging technologies. Bob is a forward thinker who keeps up with the changing landscape of technical innovation and the law surrounding the Internet of Things, blockchain, smart contracts

Bob advises clients on a range of intellectual property issues and keeps them current on emerging technologies. Bob is a forward thinker who keeps up with the changing landscape of technical innovation and the law surrounding the Internet of Things, blockchain, smart contracts and data privacy.

Photo of Malia Rogers Malia Rogers

Clients of all sizes – from innovative startups to Fortune 500 corporations – value Malia’s counsel on a broad range of privacy and cybersecurity issues, including incident response in times of emergency. She advises clients on privacy compliance planning, which encompasses cybersecurity measures…

Clients of all sizes – from innovative startups to Fortune 500 corporations – value Malia’s counsel on a broad range of privacy and cybersecurity issues, including incident response in times of emergency. She advises clients on privacy compliance planning, which encompasses cybersecurity measures as well as drafting breach response and action plans.