privacy policy

California Consumer Privacy Act (CCPA) Enforcement Date Looming

Published April 2, 2020

The California Consumer Privacy Act (“CCPA”) went into effect on January 1, 2020, and the California Attorney General can commence enforcement on July 1, 2020.  In preparation for enforcement, the AG’s office released its second modified proposed regulations on March 11, 2020 and the comment period closed on March 27, 2020.  Despite the uncertainties that businesses are currently facing with COVID-19, it appears that the AG’s office will begin enforcing the CCPA on July 1st.

Companies subject to the CCPA must have an updated privacy policy posted online covering the company’s online and offline data practices, describing the consumer rights, and how the company will handle consumer requests related to their personal information.  Although the CCPA’s private right of action is limited to security breaches, plaintiff’s attorneys have already commenced litigation to try to expand the private right of action to other (alleged) violations of the Act.

For more information on the proposed regulations, please visit the Attorney General’s website dedicated to the CCPA here.


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