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.