California Consumer Privacy Act

On August 30, 2020, the California legislature passed Assembly Bill 1281, which extends the CCPA’s business-to-business and employee exemptions by one year until January 1, 2022. The bill now moves to the California Governor’s office.
Continue Reading CCPA Update: Legislature Extends Business-to-Business and Employee Exemptions for One Year

Keypoint: Some additional changes to the CCPA regulations were made before they were filed with the Secretary of State and became effective.

As discussed in our prior post, on Friday, August 14, 2020, the California Office of Administrative Law (OAL) approved the California Office of the Attorney General’s (OAG) final CCPA regulations and filed them with the California Secretary of State (SOS). The regulations were immediately effective.

Notably, the final text of the regulations submitted to the SOS was modified from the one filed with the OAL. The OAG published an Addendum to the Final Statement of Reasons setting forth the changes. Many of the changes are stylistic and grammatical. However, some of the changes are substantive and will impact compliance efforts. The most notable changes are discussed below:


Continue Reading CCPA Update: Analyzing the Changes to the Final CCPA Regulations

On August 14, 2020, Attorney General Becerra announced that the California Office of Administrative Law (OAL) approved the final regulations related to the California Consumer Privacy Act (CCPA) an filed them with the Secretary of State. The regulations go into effect immediately.

The Attorney General’s office submitted the final proposed regulations to the OAL on June 1, 2020. As part of the final regulations package, the Attorney General requested an expedited review of 30 business days and that the regulations become effective upon filing with the Secretary of State. Although not satisfying the 30-day request, the OAL did complete its review in short order, particularly in light of two executive orders by California’s governor extending the OAL’s review period by an additional 120 days.


Continue Reading CCPA Final Regulations Approved and Effective Immediately

Over the past few months, there have been numerous developments in state, federal and international privacy law. On Wednesday, August 5, 2020, from 12:00 – 1:00 C.T. members of Husch Blackwell’s privacy and data security practice group will present a webinar providing an overview of the rapidly changing privacy law landscape.  Click here for more

During a webinar last week hosted by the International Association of Privacy Professionals, a representative from the California Attorney General’s office confirmed that on July 1, the first date of the AG’s statutory enforcement authority, the office sent its first set of CCPA enforcement letters. Per the statute, businesses have 30 days to cure the violations before the AG’s office may commence a confidential investigation or initiate a lawsuit.

Continue Reading CCPA Update: AG’s Office Confirms CCPA Enforcement Has Begun

On June 24, 2020, the California Secretary of State announced that county election officials had validated enough signatures through the random signature validation process to make the California Privacy Rights Act of 2020 (a/k/a CCPA 2.0) eligible for the November 3, 2020 ballot. The final projected valid signatures based on the random sample validation process

In early June, the California Attorney General filed final CCPA regulations with the California Office of Administrative Law. The final regulations were accompanied by a 59-page Final Statement of Reasons along with six appendices containing over 500 pages of comments on the regulations and the Attorney General’s responses to those comments. One of the many topics that the Attorney General’s office discussed was the final regulation’s requirements for drafting privacy policies. Given that the drafting of a privacy policy is a necessary part of CCPA compliance, it is worth analyzing those comments.

Continue Reading Analyzing the California Attorney General’s Comments on Drafting Privacy Policies

The California Attorney General’s office just published final CCPA regulations. The Attorney General also submitted a written justification requesting an expedited review of the regulations and an effective date upon the filing of the regulations with Secretary of State.

Join us on Friday, June 5, 2020, from noon to 1:00 CDT for a live webinar

In this 25 minute on-demand webinar, Husch Blackwell attorneys David Stauss and Malia Rogers provide an overview of the California Privacy Rights Act (CPRA or CCPA 2.0), which is currently on track to appear on the November 2020 California ballot. If passed, the CPRA will significantly amend and expand the California Consumer Privacy Act.