Covered businesses have much work to do to revise disclosures, implement choice mechanisms, and design compliant data subject request programs.

Key Points:

..The Attorney General’s draft regulations, released on October 10, 2019, will be available for public comment until December 6, 2019, after which they will likely undergo some further revisions before becoming enforceable on July 1, 2020.

..Violations of the CCPA between its January 1, 2020, effective date and the regulations’ July 1, 2020, enforcement date remain a risk, so waiting for the final rules is not a viable compliance plan.