Friday, October 11, 2019

Proposed Regulations Implementing the California Consumer Privacy Act

Image of laptop displaying eyeball and text California California's Attorney General released proposed regulations implementing the California Consumer Privacy Act yesterday (10/10), and at first glance, I'm disappointed.  I'm still digesting them, and will probably post more later, but you can read them for yourself here.  The AG's press release is here.  The AG's "Fact Sheet" is here.

The draft regulations are out for public comment until December 6. Make your voice heard! The Attorney General will consider  comments and may revise the regulations in response. Any revision will trigger an additional 15 day public comment period.  Following the comment period(s), the AG will submit the final text to the Office of Administrative Law, which has 30 business days to review the regulations before they will go into effect.  In other words, the regulations will not be final before the January 1 compliance deadline. 

Although the AG will not begin enforcing the regulations until July 7, 2020, I predict the plaintiffs' bar will be initiating actions soon after January 1. 

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