Where Are We Now? – Taking Stock of CCPA Amendments after May 31 Legislative Deadline

Akin Gump Strauss Hauer & Feld LLP
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• May 31, 2019, was the deadline for the California Legislature to pass bills out of the chamber in which they were introduced. Several measures proposing amendments to the California Consumer Privacy Act (CCPA) passed the state Assembly and now await action in the Senate.

• September 13, 2019, is the last day for any bill, including those containing CCPA amendments, to be passed this year. Negotiations have already begun regarding changes to CCPA amendments passed by the Assembly to try and ensure passage by the Senate.

• Below, we provide a practical summary of pending CCPA amendments and highlight those of particular importance. Pending CCPA amendments would, among other things, effectively remove employees from the definition of consumer, explicitly exempt deidentified and aggregate information from the definition of personal information, and exclude customer loyalty programs from certain CCPA provisions.

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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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