Photo of Megan Beebe

Megan Beebe

Whether clients are forming, growing or governing businesses, Megan assists in the corporate deals and transactions necessary to move forward. A corporate attorney, Megan focuses her practice on helping clients of all sizes – from emerging startups to international corporations – establish, grow and protect business.

Follow:Read more about Megan BeebeMegan's Linkedin Profile

Conceptual image about how a laptop computer with internet open a virtual door to worldwide information sharing.Keypoint: The modified proposed regulations make substantial changes to the proposed regulations, including modifying how consumer notices must be drafted and changing some of the requirements for receiving and responding to consumer requests.

On Friday, February 7, 2020, the California Attorney General’s office published a notice of modifications to the text of the proposed regulations regarding the California Consumer Privacy Act (CCPA). The AG’s office also published redline and clean versions of the modified regulations.

The changes modify the proposed regulations published by the Attorney General’s office on October 11, 2019. The changes are the result of four public hearings held in December 2019 and the submission of over 1,700 pages of written comments. The Attorney General’s notice states that the department will accept written comments on the proposed changes until 5:00 p.m. on February 24, 2020.

Based on guidance previously published by the Attorney General’s office, this abbreviated comment period reflects the Attorney General’s determination that the changes are “substantial and sufficiently related,” but not “major,” which would require a new 45-day comment period. Following review of written comments, the Attorney General’s office will publish an updated informative digest and final statement of reasons (with summary and response comments) in addition to the final text of the regulations.

Members of Husch Blackwell’s privacy and data security practice group will host a webinar on Wednesday, February 12 at noon CST to review and discuss the modified regulations. To register, click here.

Below is our analysis of the modified regulations.

Conceptual image about how a laptop computer with internet open a virtual door to worldwide information sharing.Keypoint: 2020 promises to be another ground-breaking year in privacy and cybersecurity law in the United States.

2019 was an exciting year in privacy and cybersecurity law. In the United States, the California Consumer Privacy Act (CCPA) was the most significant story, but there also were developments in states such as New York and Nevada. Numerous other states also considered consumer privacy legislation, and federal lawmakers even jumped into the fray, proposing a variety of bills and regulations. Overseas, GDPR garnered the most headlines of course, but other countries, such as Brazil, also made news.

But 2019 was just the start. There is no doubt that privacy and cybersecurity law is undergoing a fundamental change in the United States. If nothing else, the legal landscape of privacy law in the United States promises to look very different by the end of the year.

Below we discuss what we anticipate will be the biggest stories in 2020 and beyond.

Keypoint:  The fallout from the 2018 Cambridge Analytica incident continues with the FTC’s issuance of this unanimous opinion and order.

On December 6, the Federal Trade Commission (“FTC”) issued a unanimous opinion (the “Opinion”) finding that political consulting firm Cambridge Analytica, LLC (“Cambridge Analytica”) violated Section 5 of the Federal Trade Commission Act (“FTC Act”) (15 U.S.C. § 45) by engaging in deceptive practices to harvest personal information from tens of millions of Facebook users through a Facebook application called the “GSRApp.”