On February 10, the California Attorney General’s office released a highly anticipated updated draft of the proposed CCPA regulations. This draft corrected a version first issued on February 7, 2020. These latest updates follow the four public hearings held in December 2019 and nearly 1,700 pages of comments submitted after the AG first released the initial proposal in October 2019. While these modified regulations are still not final, some of the notable changes include:
The deadline to submit written comments is Tuesday, February 25, 2020 at 5pm PST. If no additional changes are made, a final rulemaking record will be submitted to the Office of Administrative Law. The OAL has 30 working days to review the record for approval.
Putting it Into Practice: As companies are beginning to see how CCPA compliance is playing out in practice, now is the time to conduct an initial evaluation of successes and challenges and use the opportunity to submit additional comments to the Attorney General. Organizations should continue to be mindful that additional changes may be forthcoming – with potentially not a lot of time to review before the July enforcement date.