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CPRA Update: What is a “Contractor?”

The California Privacy Rights Act (CPRA), effective January 1, 2023, adds “contractors” to the list of entities that a business may entrust with customer data. So what is a “contractor?” And how are “contractors” different...more

California Privacy Legislation Round-Up: Gov. Newsom Signs CCPA Employee Exemption Extension, Vetoes Others

Prior to the September 30 deadline to sign or veto legislation, California Governor Gavin Newsom recently took action on three bills related to data privacy. Bringing some potential certainty to the dynamic CCPA landscape,...more

FTC Seeks Rule to Collect Civil Penalties for Made in USA Labeling Violations

Further to ongoing efforts to evaluate and regulate how companies advertise and label that their products are “Made in the USA,” last week the FTC issued a staff report and a proposed rule that would include the possibility...more

CCPA Update: Final Regulations Submitted but No Changes from Prior Draft

On June 2, California Attorney General Xavier Becerra announced that he had submitted final CCPA regulations to the Office of Administrative Law (OAL) for review. The final regulations are substantively identical to the...more

The CCPA Non-Discrimination Right, Explained

The California Consumer Privacy Act (CCPA) provides consumers with a right to non-discrimination when they exercise other privacy rights guaranteed by the law, such as the right to access, delete, or opt out of the sale of...more

No Delay? What To Expect on CCPA Enforcement Timing

The CCPA grants the California Attorney General (AG) the authority to enforce the CCPA starting on July 1, 2020. Last month, the AG confirmed no intention to delay that enforcement date due to the COVID-19 pandemic, despite...more

CCPA Update: Attorney General Releases Third Draft of Proposed CCPA Regulations

On Wednesday, the California Attorney General (AG) released a third draft of proposed CCPA regulations for public comment. The draft contains a series of technical corrections, along with a handful of substantive incremental...more

CCPA Update: Data Broker Registry Now Live

The California Attorney General unveiled its data broker registry on Monday. On or before January 31st, companies qualifying as a “data broker” based on the prior year’s activities are required to register their name and...more

CCPA Implementation: An Early Map

The January 1, 2020 effective date of the California Consumer Privacy Act (CCPA) has come and gone, but questions about how to comply with the law show no hint of disappearing. As companies move past their efforts to comply...more

CCPA Update: AdTech Options to Avoid a “Sale” and What Google Has to Say About It

Last Monday, Google released its answer to the CCPA: a new “service provider” contract.  Given Google’s widely used advertising and analytics technologies, Google’s new contract has the potential to influence how website...more

CCPA Update: Prioritizing Compliance with Two Months Until the CCPA Takes Effect

In exactly two months, the California Consumer Privacy Act (CCPA) takes effect. Many businesses are devoting resources to timely comply, but between the late rollout of the Attorney General’s draft regulations, recent...more

CCPA Update: California Governor Signs Seven Amendments to the CCPA

On Friday, California Governor Gavin Newsom signed seven legislative proposals to amend the California Consumer Privacy Act (CCPA), marking the end of a nearly-yearlong process to make changes to the new privacy law before it...more

CCPA Update: California Attorney General Issues Draft Privacy Rules

On Thursday, California Attorney General Xavier Becerra released draft regulations implementing the California Consumer Privacy Act (CCPA). The regulations provide the first glimpse into how the Attorney General interprets...more

CCPA Update: Legislature Amends the CCPA to Exclude Employee Data, B2B Communications for One Year

Last week, the California legislature voted to send five amendments to the CCPA to the California governor’s desk. The amendments include a one-year exemption for access and deletion rights to employee data and B2B...more

CCPA Update: With Legislative Session to End Friday, CCPA Amendments Slated for Final Vote

This week marks the final opportunity for California lawmakers to amend the CCPA before the legislative session closes on Friday, September 13th. The legislative posture of the amendments changed last Friday, when the Senate...more

CCPA Update: California Senate Committee Approves Privacy Law Amendments

Amendments to the California Consumer Privacy Act (CCPA) continued to advance on Monday, as the California legislature returned from its summer recess. With just five weeks to go until the September 13th deadline for the...more

What Facebook’s Next 20 Years Will Look Like: Is This the Future of US Privacy?

Even in her extensive dissent, FTC Commissioner Rebecca Slaughter labeled the Order “exceptional.” And it is. The terms of the Federal Trade Commission’s (FTC) $5 billion, twenty-year settlement Order reached with...more

California Senate Committee Blesses Majority of CCPA Amendments

Seven amendments to the California Consumer Privacy Act (CCPA) are one step closer to becoming law after the California Senate Committee on the Judiciary voted to advance the legislation earlier this month....more

CCPA Update: Employee Exemption Bill Amended in Senate Committee 

California legislators are tweaking language in a proposal to exclude employee or job applicant data from the State’s landmark privacy law slated to take effect in January. The California Consumer Privacy Act (CCPA) grants...more

Senators Introduce Bipartisan Effort to Regulate Health Apps, Biometrics & Wearables

A new bill introduced in the Senate Health, Education, Labor, and Pensions (HELP) Committee would impose federal regulatory obligations on health technology businesses that collect sensitive health information from their...more

California Assembly Approves Amendments to Exclude Employees from CCPA, Protect Loyalty Programs

On Tuesday and Wednesday of this week, the California Assembly voted to approve four bills to amend the California Consumer Privacy Act (CCPA). The legislation now moves to the California Senate....more

Bills to Exclude Insurance Companies from the CCPA, Protect Loyalty Programs among Legislation Approved by California Assembly

On Wednesday, the California Assembly voted to approve two bills to amend the California Consumer Privacy Act (“CCPA”). The legislation now moves to the California Senate....more

California Senate Ends Suspense on Privacy Private Right of Action

In February, we posted that the California Attorney General and state Senator Hannah-Beth Jackson had announced a bill that would have materially expanded legal exposure for businesses under the CCPA. The most concerning...more

Court Says Headphone App Not Eavesdropping, But May Be Deceptive

A federal judge allowed a class-action lawsuit alleging Bose collected and shared data about its headphone users to proceed last week on the basis of deceptive advertising. The decision underscores the risks that internet of...more

GDPR Recap: Technical Violations Result in Steep Fines, In Latest Enforcement Actions

The Danish and Polish data protection authorities issued their first GDPR fines last month. The cases serve as indicators of the kinds of technical violations enforcement officials are looking to deter as they police the EU’s...more

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