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California Attorney General Announces Settlement with DoorDash for CCPA and CalOPPA Violations

On February 21st, the California Attorney General (AG) Rob Bonta announced a settlement with DoorDash for violations of the California Consumer Privacy Act (CCPA) and the California Online Privacy Protection Act (CalOPPA)...more

CPPA Releases Proposed Automated Decision-Making Rules

On November 27, 2023, the California Privacy Protection Agency (CPPA) published proposed Automated Decision-Making Rules to be discussed by the CCPA board at its upcoming meeting on December 8, 2023. While the proposed rules...more

CPPA publishes new draft regulations addressing AI, risk assessments, cyber audits

The California Privacy Protection Agency (CPPA) recently published two new sets of draft regulations addressing a range of cutting-edge data protection issues. Although the CPPA has not officially started the formal...more

CPPA Publishes New Draft Regulations Addressing AI, Risk Assessments, and Cyber Audits

The California Privacy Protection Agency (CPPA) recently published two new sets of draft regulations addressing a range of cutting-edge data protection issues. Although the Agency has not officially started the formal...more

California Enforcement Sweep Targets Mobile Apps – With a Focus on Honoring “Permission Slip” App

On Friday, January 27, California Attorney General Rob Bonta announced an investigative sweep of businesses that provide mobile apps, issuing warning letters to those that AG Bonta alleges failed to comply with the California...more

California Enforcement Sweep Targets Mobile Apps

On Friday, January 27, California Attorney General Rob Bonta announced an investigative sweep of businesses that provide mobile apps, issuing warning letters to those that AG Banta alleges failed to comply with the California...more

Real World Implications of Sephora

On August 24, California Attorney General Rob Bonta announced a $1.2 million settlement with Sephora over allegations that the cosmetic retailer had violated the California Consumer Privacy Act (CCPA). This first public...more

CPRA’s Employee and B2B Exemptions Appear Destined to Sunset

The August 31 closing of the California legislative session likely marked the end of hopes for an extension of the limited exemptions for employee and business-to-business (B2B) data that have existed for the California...more

Initial Thoughts About the Proposed CPRA Regulations

In a surprising development, the California Privacy Protection Agency (CPPA) published proposed amendments to the CCPA regulations recently. The proposed amendments were initially made public in a package of materials to be...more

Draft CPRA Regulations Released by CPPA

The California Privacy Protection Agency (“CPPA”) scheduled a Board Meeting for June 8th, in which it will be discussing and possibly taking action with regard to the much anticipated CPRA enforcing regulations. To...more

Predictions for Privacy & Data Security in 2022

2021 proved to be a momentous year for privacy and data security law. The scourge of ransomware continued last year, leading to record-setting ransomware payments, a muscular response from the federal government, a hardening...more

Managing Compliance with the Growing Patchwork of State Privacy Laws

Over the past four years, U.S. companies have been forced to expand their compliance programs to comply with an expanding array of international and U.S. state privacy laws. The wave of privacy laws began in May 2018, when...more

Federal Court Dismisses CCPA Claim Against Marriot International, Inc. For Lack of Standing

On January 12, 2021, the federal District Court for the Central District of California dismissed a data breach law suit—including a claim filed under the California Consumer Privacy Act (“CCPA”)—against Marriott...more

California Attorney General Shows No Sign of Slowing CCPA Rulemaking with Fourth Set of Proposed Modifications

The California Attorney General’s Office recently released a fourth set of proposed regulatory modifications to the California Consumer Privacy Act (the “CCPA”)....more

California Voters Approve CPRA

On November 4, 2020, California voters approved of the ballot initiative Proposition 24, more commonly known as the California Privacy Rights Act (the “CPRA”).  The CPRA goes into effect on January 1, 2023, and will expand...more

CCPA Regulations Go Into Effect – With a Few Final Changes

On August 14, 2020, the California Office of Administrative Law (“OAL”) approved in part and withdrew in part the Regulations regarding the California Consumer Privacy Act (“CCPA”). While most of the changes are...more

Planning for the Worst: Privacy, Info Sec, and Bankruptcy

With the ongoing covid crisis leaving businesses of all sizes concerned about the short and medium term future, the intimidating task of considering a liquidation or restructuring is inevitably starting to become a reality. ...more

Collecting Personal Information to Combat Coronavirus and the CCPA

Businesses subject to the California Consumer Privacy Act (“CCPA”) that have begun exploring the possibility of collecting data from visitors to their facilities to track potential coronavirus exposure and to allow/deny entry...more

California AG Issues Modified CCPA Regulations

On Friday, February 7, 2020, the California Attorney General’s (AG) Office released modified regulations to the California Consumer Privacy Act (CCPA).  The modified regulations incorporate amendments to the CCPA signed into...more

"Retail Rap" – Analysis of Business and Legal Trends in the Industry: November 2019

Welcome to our latest edition of Retail Rap. From influencer marketing to launching a startup and ensuring digital advertising complies with the latest regulations, retail issues are making news—and presenting legal...more

Analysis: Verifying Consumer Requests Under the CCPA

For businesses, one of the more worrisome scenarios under the CCPA occurs when they mistakenly provide personal information of a consumer to the wrong party in response to a consumer request, whether because of fraud or...more

Analysis: Notice Provisions of CCPA Proposed Regulations

To the surprise of some, the proposed CCPA Regulations issued last Thursday don’t address many of the well-discussed ambiguities under the law (such as what “valuable consideration” means in the context of a sale of personal...more

California AG Releases Proposed CCPA Regulations

The California Attorney General’s Office released its long-awaited proposed CCPA Regulations yesterday.  The proposed Regulations are 24 pages long, and address a number of important technical compliance issues including...more

California Legislature Adopts Five Amendments to CCPA, But Largely Rejects Industry Efforts

On September 13, 2019—the last day of the legislative session—California lawmakers approved five amendments intended to clarify the scope of the California Consumer Privacy Act (the “CCPA”), but rejected several...more

California Senate Judiciary Committee Advances Amendments to the CCPA

At what has been described as a marathon hearing that lasted late into the night of July 9, the California Senate Judiciary Committee advanced several amendments to the California Consumer Privacy Act (the “CCPA”), but major...more

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