September 4, 2020

The California Office of Administrative Law (OAL) approved the final proposed regulations for compliance with the California Consumer Protection Act (CCPA).  

Enforcement of the first robust data privacy law in the nation commenced on July 1, 2020.  The CCPA was enacted in 2018 and established consumer rights to access to, deletion and sharing of personal information that is collected by businesses.  Read more about the CCPA in RLF’s newsletter “Is Your Company Ready for the California Consumer Protection Act (CCPA)?” here.  

The final regulations, which were submitted to the OAL in June were modified prior to their adoption.  The modifications were generally non-substantive and removed or clarified redundant language.  The following regulations were “withdrawn for further consideration” by the Attorney General:

  • A requirement for businesses to obtain a consumer’s explicit consent to use personal information for any new purpose;
     
  • A requirement for businesses that operate offline to provide an offline notice informing consumers of their right to opt out of the sale of personal information;
     
  • A requirement that the method provided by consumers to exercise their right to opt out of the sale of personal information be “easy for consumers to execute and shall require minimal steps to allow the consumer to opt-out.”

While these regulations (and the resulting burdens on some businesses) have been withdrawn, the CCPA and the final regulations remain complex and the compliance requirements are not straightforward.  Since enforcement of the CCPA has begun, ensuring that your company understands and complies with the CCPA is more crucial than ever.  The Team at Renzulli Law Firm is working with clients around the world to ensure continued compliance with the CCPA.  If you have any questions about the CCPA, the final compliance regulations and their impact on your business contact John F. Renzulli or Christopher Renzulli.