CA Consumer Privacy Act Gets a Rewrite
MSK Client Alert
March 27, 2019
When the law was signed by then Governor Brown (see our prior Alert here), the expectation was that Attorney General Becerra would issue the enabling regulations by July of this year, which would allow a phase-in period. Then by January 1, 2020, the requirements would be clear and companies would be able to properly formulate and implement their compliance policies. Regretfully, things are not going as expected.
First, in accordance with the law, General Becerra organized a series of public meetings:
- San Francisco – January 8, 2019
- San Diego – January 14, 2019
- Inland Empire/Riverside – January 24, 2019
- Los Angeles – January 25, 2019
- Sacramento – February 5, 2019
- Fresno – February 13, 2019
In the same press release which announced these meetings, General Becerra advised the regulations would be adopted by July 1, 2020 and went on to remind businesses that they must comply with the key provisions of the CCPA by January 1, 2020:
- Disclose data collection and sharing practices;
- Consumers have a right to request their data be deleted;
- Consumers have a right to opt out of the sale or sharing of their personal information; and
- Businesses are prohibited from selling personal information of consumers under the age of 16 without explicit consent.