First Impressions: California Attorney General Issues Draft CCPA Regulations

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Fox Rothschild LLPThe California Attorney General has issued long-awaited draft regulations for the California Consumer Privacy Act (CCPA), which is scheduled to take effect in 2020.

High level takeaways:
  • Big emphasis on disclosure and transparency: both format and content of the privacy notices.
  • Separation between the privacy notice for “at or before collection of information” and the “website privacy policy.”
  • Emphasis on reasoning for taking actions (e.g. not deleting per request, etc.).
  • Specific instructions on how to respond to requests (Hint: can’t wait until day 44 to reply).
  • Guidance on timing for response (Hint: time needed to verify does not extend the 45 days).
  • Detailed guidance on how to verify the identity of a requesting consumer.
  • Expanded requirements for companies collecting information of 4 million or more consumers (Hint: disclose stats on consumer requests and median time it takes to respond).
  • Guidance on the methods for exercising the rights.
  • Detailed guidance on how to calculate the value of the consumer’s information in order to provide a legal financial incentive.
  • Detailed guidance re: CCPA-specific training.
  • New records retention requirement for consumer request logs.
  • Possible to express an opt-out request through browser preferences/user-enabled privacy controls.

Read the full text of the draft regulations.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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